Memorandum Opinion
GOLDBERG, Special Trial Judge:
This case was considered pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986.
Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $124,042.30. This case is before the Court on Respondent's Motion For Partial Summary Judgment pursuant to Rule 121. The motion was filed on February 1, 1988, together with...
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