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ESTATE OF ARNAUD v. C.I.R.

No. 88-7479.

895 F.2d 624 (1990)

ESTATE OF Jean Simon Andre ARNAUD, Deceased; Emile Furlan, Executor, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided February 7, 1990.

Attorney(s) appearing for the Case

A. Thomas Murphy, San Francisco, Cal., for petitioners-appellants.

Regina S. Moriarty, Kim Stanley, Tax Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before SNEED, HUG and LEAVY, Circuit Judges.

HUG, Circuit Judge:

Appellant-Taxpayer, the Estate of Jean Simon Andre Arnaud, appealed from an adverse decision issued by the Tax Court. Arnaud was, at the time of his death, a nonresident alien domiciled in France. The issue on this appeal is whether a tax treaty between France and the United States ("French Tax Treaty")1 entitles the Estate of Arnaud ("Taxpayer") to compute the estate tax utilizing...

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