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ESTATE OF NOWELL v. COMMISSIONER

Docket No. 19056-96.

77 T.C.M. 1239 (1999)

T.C. Memo. 1999-15

Estate of Ethel S. Nowell, Deceased, David A. Prechel, Personal Representative v. Commissioner.

United States Tax Court.

Filed January 26, 1999.

Attorney(s) appearing for the Case

Alfred J. Olsen, Phoenix, Ariz., James J. Rossie, Jr., Stephen E. Silver, Brad S. Ostroff, and Martha C. Patrick for the petitioner. Rick V. Hosler, for the respondent.

MEMORANDUM OPINION

COHEN, Chief Judge:

This case is before the Court on cross-motions for partial summary judgment under Rule 121. Respondent determined a deficiency of $342,688 in the Federal estate tax of the estate of Ethel S. Nowell (decedent). The issues for decision are: (1) Whether certain partnership interests includable in the gross estate pursuant to section 2044 should be merged or aggregated with the partnership interests includable in the gross...

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