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ESTATE OF WINEMAN v. COMMISSIONER

Docket No. 27339-96.

79 T.C.M. 2189 (2000)

T.C. Memo. 2000-193

Estate of Rebecca A. Wineman, Deceased, Eleanor Truocchio and Dean Wineman, Co-Executors v. Commissioner.

United States Tax Court.

Filed June 28, 2000.

Attorney(s) appearing for the Case

John W. Ambrecht, Santa Barbara, Calif., and Gregory Arnold, for the petitioner. Steven M. Roth, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge:

Respondent determined an estate tax deficiency of $775,626 and an addition to tax under section 6662 of $3,844. After concessions,1 the issues for decision are:

1) Whether Rebecca A. Wineman (decedent) retained a life estate in partial interests in her homestead property transferred to her children. We hold that she did not.

2) Whether decedent rented her...

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