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ESTATE OF BLACK v. COMMISSIONER OF INTERNAL REVENUE

No. 23516-06.

T.C. Memo. 2012-63

ESTATE OF IRENE M. BLACK, DECEASED, SAMUEL P. BLACK, III, EXECUTOR, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed March 8, 2012.

Attorney(s) appearing for the Case

John W. Porter , for petitioner.

Gerald A. Thorpe , for respondent.

SUPPLEMENTAL MEMORANDUM OPINION

HALPERN, Judge.

This matter is before us as a result of the parties' dispute over the proper computations for entry of decision under Rule 1551 in connection with our Opinion in Estate of Black v. Commissioner, 133 T.C. 340 (2009) (Estate of Black I or our prior Opinion).

Background

In our prior Opinion...

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