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ESTATE OF LEACH v. COMMISSIONER

Docket Nos. 2243-81, 2244-81.

82 T.C. 952 (1984)

ESTATE OF ANNE B. LEACH, DECEASED, GEORGE HOWE BAILEY, JR., ADMINISTRATOR AD LITEM, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 14, 1984.

Attorney(s) appearing for the Case

Robert O. Rogers, for the petitioner.

Stuart B. Kalb, for the respondent.

OPINION

SWIFT, Judge:

Respondent, in statutory notices mailed to petitioner on November 7, 1980, determined a deficiency in petitioner's Federal estate tax liability of $740,937, and deficiencies in petitioner's Federal income tax liabilities of $102 for 1977 and $18,712 for 1978.

Following concessions by the parties, the issues remaining for decision are (1) whether certain annuities, payable by three...

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