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ESTATE OF KORBY v. COMMISSIONER

Dkt. No. 18452-02.

89 T.C.M. 1150 (2005)

T.C. Memo. 2005-103

Estate of Austin Korby, Deceased, Austin Korby, Jr., Trustee of the Austin and Edna Korby Living Trust, and Estate of Austin Korby, Deceased, Transferor, Austin Korby, Jr., Trustee of the Austin and Edna Korby Living Trust, Transferee, Petitioners v. Commissioner, Respondent

United States Tax Court.

May 10, 2005.

Attorney(s) appearing for the Case

David W. Johnson and James A. Beitz, for petitioners;

Helen H. Keuning, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GOEKE, Judge:

Respondent determined a deficiency of $1,070,482 in the Federal estate tax of the Estate of Austin Korby (the estate).1 After concessions, there are two issues remaining for decision.

(1) Is the value of the assets Austin and Edna Korby (Austin and Edna or the Korbys) transferred to the Korby Properties, A Limited Partnership...

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