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ESTATE OF ARNAUD v. COMMISSIONER

Docket No. 39812-85.

90 T.C. 649 (1988)

ESTATE OF JEAN SIMON ANDRE ARNAUD, DECEASED, EMILE FURLAN, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 7, 1988.

Attorney(s) appearing for the Case

A. Thomas Murphy, for the petitioner.

Charlotte Mitchell, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax of $51,834.44. After concessions by the parties, the issues for decision are: (1) Whether petitioner is entitled, under the United States-France estate tax convention (the French treaty)1 to the unified credit against estate tax allowed by section 2010;2 and, if not, (2) whether the tentative estate...

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