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ESTATE OF HUBERT v. COMMISSIONER

Docket No. 22333-90.

101 T.C. 314 (1993)

ESTATE OF OTIS C. HUBERT, DECEASED, C&S/SOVRAN TRUST COMPANY (GEORGIA), N.A., A NATIONAL BANKING ASSOCIATION, CO-EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 19, 1993.

Attorney(s) appearing for the Case

David W. Aughtry, David W. Seigel, and James M. McCarten, for petitioner.

Willard N. Timm, Jr., for respondent.

OPINION

CLAPP, Judge:

Respondent determined a deficiency in petitioner's estate tax in the amount of $14,052,146. After concession by the parties, the remaining issues for decision are: (1) Whether the amounts of petitioner's marital and charitable deductions are limited to the amounts passing to the marital and charitable shares under the 1982 will and three codicils, or are the amounts actually passing...

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