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ESTATE OF BALLARD v. COMMISSIONER

Docket No. 32658-83.

85 T.C. 300 (1985)

ESTATE OF CLAIRE M. BALLARD, DECEASED, SHIRLEY A. WEBSTER, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 20, 1985.

Attorney(s) appearing for the Case

G. Stephen Walters and Shirley A. Webster, for the petitioner.

Bruce W. Baker, for the respondent.

OPINION

DAWSON, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $17,931. Two issues are presented for decision: (1) Whether the tax paid by petitioner to Canada is an estate tax for which a credit is allowable under section 2014(a);1 and (2) whether the tax paid by petitioner to Canada is a tax of substantially similar character to...

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