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ESTATE OF BURGHARDT v. COMMISSIONER

Docket No. 20766-81.

80 T.C. 705 (1983)

ESTATE OF CHARLOTTE H. BURGHARDT, DECEASED, RALPH KIMM, ANCILLARY ADMINISTRATOR, C.T.A., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 11, 1983.

Attorney(s) appearing for the Case

Erik J. Stapper, for the petitioner.

Vincent R. Barrella, for the respondent.

OPINION

TANNENWALD, Chief Judge:

Respondent determined a deficiency of $4,983.11 in petitioner's Federal estate tax. The sole issue for decision is whether petitioner, the estate of a nonresident alien, is entitled, under the estate tax convention between the United States and the Republic of Italy (the Italian treaty),1 to a percentage of the unified credit available to estates...

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