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ESTATE OF POWELL v. COMMISSIONER

Docket Nos. 24703-12, 24731-12..

148 T.C. 392 (2017)

148 T.C. No. 18

ESTATE OF NANCY H. POWELL, DECEASED, JEFFREY J. POWELL, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 18, 2017.

Attorney(s) appearing for the Case

David B. Shiner, for petitioner.

Gorica B. Lakic and Alexander R. Roche, for respondent.

OPINION

By separate notices of deficiency, respondent determined a deficiency of $5,870,226 in the Federal estate tax of the Estate of Nancy H. Powell (decedent) and a deficiency of $2,961,366 in decedent's Federal gift tax for 2008. The estate has moved for summary judgment in its favor that there is no deficiency in either...

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