Docket No. 20857-94.

72 T.C.M. 687 (1996)

T.C. Memo. 1996-426

Estate of Helen G. Williamson, Deceased, Douglas F. Woods, Executor v. Commissioner.

United States Tax Court.

Filed September 19, 1996.

Attorney(s) appearing for the Case

Richard J. Sideman, San Francisco, Calif., and Wendy Abkin, for the petitioner.

Elizabeth L. Groenewegen and Rebecca T. Hill, for the respondent.


KORNER, Judge:

This case is before the Court on petitioner's motion for partial summary judgment under Rule 121.

All statutory references are to the Internal Revenue Code in effect as of the date of decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure, except as otherwise noted.

Harry and Helen Williamson (decedent) were married in California in 1947, and resided in California until...

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