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ESTATE OF TEHAN v. COMMISSIONER

Dkt. No. 17282-03.

89 T.C.M. 1374 (2005)

T.C. Memo. 2005-128

Estate of Timothy J. Tehan, Deceased, Timothy R. Tehan, Executor v. Commissioner.

United States Tax Court.

May 31, 2005.

Attorney(s) appearing for the Case

Michael F. Callahan, for petitioner;

William J. Gregg and Ann Welhaf, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge:

Respondent determined a deficiency of $132,415 in Federal estate tax (estate tax) with respect to the estate (estate) of Timothy J. Tehan (decedent).

The issues remaining for decision are:

(1) Is certain property includible in decedent's gross estate under section 2036(a)(1)?1 We hold that it is.

(2) Is the estate entitled to deduct under section...

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