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ESTATE OF RAVETTI v. COMMISSIONER

Docket No. 2913-87.

64 T.C.M. 1476 (1992)

T.C. Memo. 1992-697

Estate of Silvio Ravetti, Deceased, Donna Logan, Executrix v. Commissioner.

United States Tax Court.

Filed December 7, 1992.

Attorney(s) appearing for the Case

Richard H. Foster, 111 Pine St., San Francisco, Calif., for the petitioner. Paul J. Krug, for the respondent.

Memorandum Opinion

WOLFE, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183. All section references are to the Internal Revenue Code in effect for the tax years at issue, unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure.

This case is before this Court on petitioner's second motion for leave to file amendment to the petition, and...

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