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ESTATE OF PLESSEN v. COMMISSIONER

Docket No. 51158.

25 T.C. 1301 (1956)

ESTATE OF ELEANOR G. PLESSEN, DECEASED, THE BANK OF NEW YORK, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 26, 1956.

Attorney(s) appearing for the Case

Donald M. Harris, Esq., for the petitioner.

James J. Quinn, Esq., for the respondent.

OPINION.

RICE, Judge:

This proceeding involves a deficiency in estate tax in the amount of $7,075.60, determined by respondent under the provisions of the 1939 Code.

The sole issue is whether the Estate of Eleanor G. Plessen is entitled to a deduction for property previously taxed in a prior decedent's estate as provided in section 812 (c),1 measured by the full value of such property or whether such deduction...

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