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ESTATE OF EDWARDS v. COMMISSIONER

Docket No. 8214-93.

74 T.C.M. 748 (1997)

T.C. Memo. 1997-443

Estate of Arthur C. Edwards, Deceased, Kenneth Edwards, Edward Edwards and James Edwards, As Trustees of the Arthur C. Edwards Settlement Trust, Personal Representative v. Commissioner.

United States Tax Court.

Filed September 29, 1997.

Attorney(s) appearing for the Case

Owen G. Fiore and Glenn M. Alperstein, Encino, Calif., for the petitioner. Debra Lynn Reale and S. Katy Lin, for the respondent.

MEMORANDUM OPINION

FAY, Judge:

This case is before us on petitioner's motion for summary judgment pursuant to Rule 121.1 Respondent filed a response in opposition to petitioner's motion. Both petitioner and respondent submitted memoranda in support of their positions.

Respondent determined a deficiency in petitioner's Federal estate tax of $14,107,060. The deficiency was due primarily to respondent's increased valuation...

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