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ESTATE OF SILVER v. COMMISSIONER

Docket No. 10125-01.

120 T.C. 430 (2003)

120 T.C. No. 14

ESTATE OF AVROM A. SILVER, DECEASED, BONNY FERN SILVER, KENNETH KIRSH, AND RONALD FAUST, EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 14, 2003.

Attorney(s) appearing for the Case

Edward C. Northwood, for petitioner.

Kevin M. Murphy, for respondent.

OPINION

VASQUEZ, Judge:

Respondent determined a deficiency of $105,3251 in the Federal estate tax of the Estate of Avrom A. Silver (decedent). The issue for decision is whether the estate of decedent, who was not a citizen of the United States and did not reside in the United States, is entitled to a charitable contribution deduction on the estate tax return (of more than the amount allowed by respondent) pursuant to the...

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