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SMITH v. COMMISSIONER

Docket No. 19200-94.

82 T.C.M. 909 (2001)

T.C. Memo. 2001-303

Estate of Algerine Allen Smith, Deceased, James Allen Smith, Executor v. Commissioner.

United States Tax Court.

Filed November 21, 2001.

Attorney(s) appearing for the Case

Harold A. Chamberlain and Michael C. Riddle, Larchmont, New York, for the petitioner. R. Scott Shieldes, for the respondent.

SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge:

This case is before the Court on remand from the Court of Appeals for the Fifth Circuit for further consideration consistent with its opinion in Estate of Smith v. Commissioner [2000-1 USTC ¶ 50,147], 198 F.3d 515 (5th Cir. 1999), reversing our decision in [Dec. 52,069] 108 T.C. 412 (1997), regarding the deductible...

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