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STRANGI v. COMMISSIONER OF INTERNAL REVENUE

No. 03-60992.

429 F.3d 1154 (2005)

ALBERT STRANGI, Deceased, Rosalie Gulig, Independent Executrix, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

November 7, 2005.

Attorney(s) appearing for the Case

Norman Arthur Lofgren, George Tomas Rhodus, Michael C. Kelsheimer, Looper Reed & McGraw, Dallas, TX, for Strangi.

Michael J. Haungs, John A. Nolet, Jonathan S. Cohen, Tax Div., App. Section, Eileen J. O'Connor, Asst. Atty. Gen., U.S. Dept. of Justice, Charles Casazza, Clerk, U.S. Tax Court, Emily A. Parker, IRS, Washington, DC, for C.I.R.

Milford B. Hatcher, Jr., Jones Day, Atlanta, GA, for American College of Trust and Estate Counsel, Amicus Curiae.

Before REAVLEY, JOLLY and PRADO, Circuit Judges.

ON PETITION FOR REHEARING

PER CURIAM:

IT IS ORDERED that the unopposed petition for rehearing is GRANTED. This case is REMANDED to the Tax Court for the limited purpose of determining allowable administrative expenses, including attorney...

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