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O'REILLY v. COMMISSIONER

Docket Nos. 16353-89, 16354-89.

67 T.C.M. 2176 (1994)

T.C. Memo. 1994-61

Charles H. O'Reilly, Sr. v. Commissioner. Alma M. O'Reilly v. Commissioner.

United States Tax Court.

Filed February 17, 1994.

Attorney(s) appearing for the Case

James F. McLeod and Vincent Tyndall, 1845 S. National Ave., Springfield, Mo., for the petitioners. Michael L. Boman, for the respondent.

Supplemental Memorandum Opinion

TANNENWALD, Judge:1

These cases are before the Court on remand from the Court of Appeals for the Eighth Circuit in O'Reilly v. Commissioner [92-2 USTC ¶ 60,111], 973 F.2d 1403 (8th Cir. 1992), revg. [Dec. 47,047] 95 T.C. 646 (1990). The sole issue for decision is the value of gifts of remainder interests in trusts of...

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