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ESTATE OF STEWART v. COMMISSIONER

Docket No. 11849-81, 11986-81.

79 T.C. 1046 (1982)

ESTATE OF ROBERT H. STEWART, DECEASED, ROBERT E. STEWART AND MARY JUNE STEWART ROBERTS, COEXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 22, 1982.

Attorney(s) appearing for the Case

Lester M. Ponder, Robert S. Ashby, Michael R. Fruehwald, and Don Hubert Wickens, for the petitioners.

Elsie Hall and Russell D. Pinkerton, for the respondent.

OPINION

FAY, Judge:

In these consolidated cases, respondent determined a deficiency of $97,871.17 in the Federal estate tax for the Estate of Robert H. Stewart (Mr. Stewart), a deficiency of $27,000.23 in Mr. Stewart's gift tax for the calendar quarter ending December 31, 1976, and an addition to gift tax of $6,750.06 under section 6651(a)(1).1 After concessions, the remaining issues are (1) whether Mr. Stewart transferred...

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