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ESTATE OF SOWELL v. COMMISSIONER

Docket No. 14216-78.

74 T.C. 1001 (1980)

ESTATE OF IDA MAUDE SOWELL, HOMER T. SOWELL, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 7, 1980.

Attorney(s) appearing for the Case

Kendall O. Schlenker and Patricia Tucker, for the petitioner.

Glenn D. Wilkinson, for the respondent.

OPINION

STERRETT, Judge:

By letter dated October 5, 1978, respondent determined a deficiency of $101,104.78 in estate taxes resulting from an adjustment of $319,054.54 increase in the gross estate due to including the corpus of a trust created by Thomas R. Sowell.

A petition for redetermination of the deficiency was filed timely. Thereafter, both parties filed a motion for summary judgment pursuant...

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