Memorandum Opinion
CLAPP, Judge:
Respondent determined a deficiency in the Federal income tax of the Estate of Helen Barrow Berger in the amount of $15,351.53 for the year 1982. The issues are (1) whether petitioner is an estate or a trust for Federal income tax purposes; and (2) whether petitioner is entitled to a charitable deduction under either section 170 or 642(c) for the portion of a capital gain ultimately designated for charities. All section references...
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