ESTATE OF MITCHELL v. COMMISSIONER

Docket No. 21805-93.

83 T.C.M. 1524 (2002)

T.C. Memo. 2002-98

Estate of Paul Mitchell, Deceased, Patrick T. Fujieki, Executor v. Commissioner.

United States Tax Court.

Filed April 9, 2002.


Attorney(s) appearing for the Case

David Wing Keong Wong, Miriam Louise Fisher, Karen L. Hirsh, and Melvin E. Lefkowitz, for the petitioner.

Henry E. O'Neill, Alan Summers, and Paul G. Robeck, for the respondent.


SUPPLEMENTAL MEMORANDUM OPINION

JACOBS, Judge:

This case is before us on remand from the Court of Appeals for the Ninth Circuit. Estate of Mitchell v. Commissioner [2001-1 USTC ¶ 60,403], 250 F.3d 696 (9th Cir. 2001), affg. [Dec. 50,205] 103 T.C. 520 (1994) and vacating and remanding [Dec. 52,297(M)] T.C. Memo. 1997-461. The Court of Appeals...

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