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ESTATE OF SULLIVAN v. COMMISSIONER

Docket No. 12084-91.

66 T.C.M. 1329 (1993)

T.C. Memo. 1993-531

Estate of Virgil C. Sullivan, Deceased, James W. Peter, Personal Representative v. Commissioner.

United States Tax Court.

Filed November 17, 1993.

Attorney(s) appearing for the Case

Charles T. Parks, Jr., David J. Shannon, Richard C. Schmoker, and David R. Brennan, 90 S. Seventh St., Minneapolis, Minn., for the petitioner. Genelle F. Forsberg, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent, by means of a statutory notice of deficiency, determined a $510,581 Federal estate tax deficiency. The issue for our consideration is whether within the meaning of section 2036(a)1 Virgil C. Sullivan (decedent) retained the possession or enjoyment of, or the right to the income from, transferred trust assets....

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