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ESTATE OF GILLESPIE v. COMMISSIONER

Docket No. 5944-92.

103 T.C. 395 (1994)

ESTATE OF PAULINE BROWN GILLESPIE, DECEASED, JAMES PAUL GILLESPIE, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 25, 1994.

Attorney(s) appearing for the Case

Juandell D. Glass, for petitioner.

Osmun R. Latrobe, for respondent.

OPINION

LARO, Judge:

This case is currently before the Court on the parties' cross-motions for summary judgment under Rule 121.1 The parties' motions indicate that there is no genuine issue as to any material fact and that a decision may be rendered through summary adjudication.2 We agree. The case is ripe for summary adjudication. The sole issue for decision is whether a "30-day letter"

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