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ESTATE OF GIULIANI v. COMMISSIONER

Docket Nos. 29790, 34726, 34839.

11 T.C.M. 673 (1952)

Estate of Joseph G. Giuliani, Deceased, Alfida E. Giuliani, Surviving Spouse v. Commissioner. Alfida E. Giuliani, Transferee v. Commissioner. Carol J. Giuliani, Transferee v. Commissioner.

United States Tax Court.

Entered June 26, 1952.

Attorney(s) appearing for the Case

John E. Dwyer, Esq., Washington Bldg., Washington, D. C., and Donald M. Sullivan, Esq., for the petitioners. Paul E. Waring, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

These proceedings, consolidated for hearing, involve a deficiency of $19,477.53 in estate tax and transferee liability therefor. The petitioners in Docket Nos. 34726 and 34839 admit liability as transferees for any deficiency in estate tax, plus statutory interest, determined herein against the estate of the decedent.

The issues are whether respondent erred in including in the gross estate the...

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