Supplemental Memorandum Opinion
NIMS, Judge:
This consolidated case is before us on remand from the United States Court of Appeals for the Sixth Circuit. In a published opinion decided and filed November 26, 1984, the Court of Appeals reversed the opinion of this Court and remanded the case for further consideration consistent with the Circuit Court's opinion. Estate of Kaplin v. Commissioner [85-1 USTC ¶ 9127],
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