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ESTATE OF HELLER v. COMMISSIONER

Docket No. 11390-12.

147 T.C. 370 (2016)

147 T.C.No. 11

ESTATE OF JAMES HELLER, DECEASED, BARBARA H. FREITAG, HARRY H. FALK, AND STEVEN P. HELLER, CO-EXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 26, 2016.

Attorney(s) appearing for the Case

Christopher W. Campbell , Ryan M. Austin , and Theresa R. Clardy , for petitioners.

Peter N. Scharff , for respondent.

OPINION

This matter is before the Court pursuant to Rule 121 on the estate's motion for summary judgment and respondent's motion for partial summary judgment.1 After concessions, the sole issue for decision is whether the estate is entitled to a section 2054 deduction.

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