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ESTATE OF LOPES v. COMMISSIONER

Docket No. 5012-98.

78 T.C.M. 46 (1999)

T.C. Memo. 1999-225

Estate of Ambrosina Blanche Lopes, Deceased, James W. Lopes, Trustee v. Commissioner.

United States Tax Court.

Filed July 8, 1999.

Attorney(s) appearing for the Case

Paul J. Barulich, Redwood City, Calif., for the petitioner. Marion T. Robus, for the respondent.

MEMORANDUM OPINION

GERBER, Judge.

This case is before the Court on cross-motions for partial summary judgment under Rule 121.1 Respondent determined a deficiency of $4,210,985 in the Federal estate tax of the Estate of Ambrosina Blanche Lopes (decedent). The sole issue for our consideration is whether fractional ownership interests in realty held in a survivor's trust and in a...

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