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ESTATE OF WATERS v. COMMISSIONER

Docket No. 28290-92.

67 T.C.M. 2837 (1994)

T.C. Memo. 1994-194

Estate of James H. Waters, Jr., Deceased, William Rogers Waters and John B. McMillan, Co-Executors v. Commissioner.

United States Tax Court.

Filed April 28, 1994.

Attorney(s) appearing for the Case

John C. Dorsey, 3605 Glenwood Avenue, Raleigh, N.C., for the petitioner. Ross A. Rowley, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

By notice of deficiency dated October 2, 1992, respondent determined a deficiency in the estate tax of the Estate of James H. Waters, Jr., deceased, in the amount of $399,519. After certain concessions and stipulations by the parties, the following issues remain for us to decide:

(1) Whether decedent's interest in his deferred compensation agreement with Boddie-Noell Enterprises, Inc., and...

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