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ESTATE OF SPEAR v. COMMISSIONER

Docket No. 3276-87.

71 T.C.M. 2512 (1996)

T.C. Memo. 1996-137

Estate of Leon Spear, Deceased, Jeanette Spear, Harvey Spear and Robert Spear, Administrators, and Jeanette Spear v. Commissioner.

United States Tax Court.

Filed March 19, 1996.

Attorney(s) appearing for the Case

Barry A. Furman, Patrick W. Kittredge, and Michael S. Paul, for the petitioners. Michael P. Corrado, Ruth M. Spadaro, and James C. Fee, Jr., for the respondent.

SUPPLEMENTAL MEMORANDUM OPINION

COLVIN, Judge:

This matter is before the Court on remand from the U.S. Court of Appeals for the Third Circuit in Spear v. Commissioner [94-2 USTC ¶ 50,605], 41 F.3d 103 (3d Cir. 1994), vacating and remanding [Dec. 49,041(M)] T.C. Memo. 1993-213.

The issues for decision on remand are:

1. Whether petitioners had any cash on hand...

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