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  5. 76 T.C.M. 409 (1998)
 

ESTATE OF HONORE V. DE ST. AUBIN v. COMMISSIONER

Docket Nos. 39493-87, 32807-88, 32808-88, 32809-88, 32811-88, 32926-88, 32994-88, 32995-88, 32996-88.

76 T.C.M. 409 (1998)

T.C. Memo. 1998-323

Estate of Honore V. de St. Aubin, Deceased, Ovide E. de St. Aubin, Executor, et al [VV] v. Commissioner.

United States Tax Court.

September 14, 1998.

Attorney(s) appearing for the Case

Joseph M. Persinger, Jonathan G. Blattmachr, and Jessica A. Feder, for the petitioners. Jill A. Frisch, Howard J. Berman, Steven Winningham, and Robert B. Marino, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHALEN, Judge:

Pursuant to Rule 121, this matter is before the Court on petitioners' motion for partial summary judgment and respondent's cross-motion for partial summary judgment. The motions raise three issues: (1) Whether Honore V. de St. Aubin, as the income beneficiary of both the marital trust and the residuary trust to be established under her husband's will...

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