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KERR v. COMMISSIONER

Docket No. 14449-98.

113 T.C. 449 (1999)

BAINE P. AND MILDRED C. KERR, DONORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 23, 1999.

Attorney(s) appearing for the Case

John W. Porter, for petitioners.

Lillian D. Brigman and John D. Maceachen, for respondent.

OPINION

JACOBS, Judge:

This matter is before the Court on petitioners' motion for partial summary judgment, filed pursuant to Rule 121.1 Petitioners contend that they are entitled to partial summary judgment that section 2704(b) is not applicable in valuing the limited partnership interests that they transferred to their grantor retained annuity trusts and to their children during 1994 and 1995.2

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