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ESTATE OF WILSON v. COMMISSIONER

Docket No. 3524-90.

64 T.C.M. 576 (1992)

T.C. Memo. 1992-479

Estate of Irvin I. Wilson, Jr., Deceased, Catherine L. Wilson, Personal Representative v. Commissioner.

United States Tax Court.

Filed August 24, 1992.

Attorney(s) appearing for the Case

Jay I. Bartz, 7373 N. Scottsdale Rd., Scottsdale, Ariz., Yale F. Goldberg, Michael W. Murphy, and David R. Frazer, for the petitioner. Mary P. Kimmel, for the respondent.

Memorandum Findings of Fact and Opinion

RUWE, Judge:

Respondent determined a deficiency of $3,099,426 in petitioner's Federal estate taxes. After a concession by petitioner, the sole issue for decision is whether decedent's interest in a trust, which passed to his wife upon his death, qualifies for the marital deduction under section 2056(a).1

Findings of Fact

Some of the facts have been stipulated and are so...

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