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ESTATE OF POWELL v. COMMISSIONER

Docket No. 10600-89.

63 T.C.M. 3192 (1992)

T.C. Memo. 1992-367

Estate of Marion I. Powell, Deceased, Southeast Bank, N.A., Harold L. Powell, Jr., and William R. Powell, Co-Personal Representatives v. Commissioner.

United States Tax Court.

Filed June 29, 1992.

Attorney(s) appearing for the Case

David G. Budd, 1010 Fifth Ave. South, Naples, Fla., for the petitioner. James P. Dawson, for the respondent.

Memorandum Findings of Fact and Opinion

HALPERN, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax liability of $68,029.73. Certain items having been conceded or settled, the only issue remaining for decision is whether the residence located at 1300 Marlin Drive, Naples, Florida, is to be included in the gross estate pursuant to section 2036.1

Findings of Fact

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