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ESTATE OF BAILLY v. COMMISSIONER

Docket No. 9487-81.

81 T.C. 949 (1983)

ESTATE OF PIERRE L. BAILLY, DECEASED, DANTE M. FIORINI, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 12, 1983.

Attorney(s) appearing for the Case

James Curtis Wood, for the petitioner.

Kathleen E. Whatley, for the respondent.

SUPPLEMENTAL OPINION

DAWSON, Chief Judge:

This case is before us on petitioner's motion for reconsideration of our opinion in the above-entitled case, 81 T.C. 246 (1983). Under the facts of this case, Dante M. Fiorini (petitioner), personal representative of the Estate of Pierre J. Bailly, deceased, properly elected under section 61661 to pay the estate tax liability in 10 equal installments...

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