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ESTATE OF COON v. COMMISSIONER

Docket No. 5758-81.

81 T.C. 602 (1983)

ESTATE OF CATHERINE E. COON, DECEASED, FRANK J. COON, ADMINISTRATOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 22, 1983.

Attorney(s) appearing for the Case

Sam Harrod III, for the petitioner.

Michael W. Bitner, for the respondent.

COHEN, Judge:

In a statutory notice of deficiency dated December 30, 1980, respondent determined a deficiency in the amount of $98,916.30 in estate taxes due from petitioner estate. After concessions, the sole issue for resolution is whether, during the 8-year period ending on the date of decedent Catherine E. Coon's death, there were periods aggregating 5 or more years during which the decedent or a member of decedent's family "materially participated" in...

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