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ESTATE OF SIMMIE v. COMMISSIONER

Docket No. 8637-74.

69 T.C. 890 (1978)

ESTATE OF ELFRIDA G. SIMMIE, DECEASED, JAMES H. HAYS, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 6, 1978.

Attorney(s) appearing for the Case

Michael L. Curtis, for the petitioner.

Peter D. Bakutes, for the respondent.

OPINION

IRWIN, Judge:

Respondent determined a deficiency of $21,783.72 in the estate tax of the Estate of Elfrida G. Simmie (hereafter decedent) who died on February 25, 1971. The parties are agreed that there is an error in the factor used in calculating the deficiency.

There are two issues for determination:

(1) Whether the valuation of decedent's life interest should be computed with the...

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