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MOSHER v. COMMISSIONER

Docket No. 18283-84.

56 T.C.M. 257 (1988)

T.C. Memo. 1988-448

Estate of Bertha B. Mosher, Deceased, Jay M. Mosher, Jr., and Arlene M. Siemers, Co-Executors v. Commissioner.

United States Tax Court.

Filed September 20, 1988.

Attorney(s) appearing for the Case

Thomas R. Beirne, 90 Maple Ave., White Plains, N.Y., for the petitioner. Laurence A. Hoch and Bernard Goldstein, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

This matter is before the Court on petitioner's Motion for Recovery of Litigation Costs Pursuant to Rule 232,1 filed February 29, 1988. Respondent, upon the order of this Court, filed a written response dated July 27, 1988, to petitioner's motion.

Findings of Fact

On July 29, 1981, petitioner filed its Federal estate tax return, Form 706, which indicated...

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