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ESTATE OF BLACKFORD v. COMMISSIONER

Docket No. 3212-80.

77 T.C. 1246 (1981)

ESTATE OF ELIZA W. BLACKFORD, DECEASED, BANK OF CHARLES TOWN, ADMINISTRATOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 8, 1981.

Attorney(s) appearing for the Case

Dennis J. McLoughlin and Lewis M. Costello, for the petitioner.

Thomas C. Morrison, for the respondent.

OPINION

STERRETT, Judge:

By statutory notice dated December 6, 1979, respondent determined a deficiency in petitioner's Federal estate tax in the amount of $9,476.06. After concessions, the sole issue for our decision is whether petitioner is entitled to a charitable deduction under section 2055, I.R.C. 1954, for amounts passing to qualifying charitable beneficiaries after the termination of a life estate.

The facts have been fully stipulated...

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