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ESTATE OF JACKSON v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 17152-13.

T.C. Memo. 2021-48

ESTATE OF MICHAEL J. JACKSON, DECEASED, JOHN G. BRANCA, CO-EXECUTOR AND JOHN McCLAIN, CO-EXECUTOR, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 3, 2021.

Attorney(s) appearing for the Case

Avram Salkin , Steven R. Toscher , Robert Samuel Horwitz , Lacey E. Strachan , Howard L. Weitzman , Jeryll S. Cohen , Sharyn M. Fisk , Paul Gordon Hoffman , Edward M. Robbins Jr. , and Loretta Siciliano , for petitioners.

Donna F. Herbert , Ray Malone Camp , Sebastian Voth , Jorden S. Musen , and Denise H. Larson , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

"The arts . . . proceed by the use of reason to the selection and adoption of what is appropriate, and to the avoidance and rejection of what is alien to themselves, contemplate the one class of objects with direct intent and by preference, and yet incidentally contemplate the other...

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