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ESTATE OF D'AMBROSIO v. COMMISSIONER

Docket No. 6724-94.

105 T.C. 252 (1995)

ESTATE OF ROSE D'AMBROSIO, DECEASED, VITA D'AMBROSIO, EXECUTRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 25, 1995.

Attorney(s) appearing for the Case

Harvey R. Poe, for petitioner.

Frank A. Racaniello, for respondent.

OPINION

LARO, Judge:

The parties submitted this case to the Court without trial. Rule 122. The Estate of Rose D'Ambrosio, Deceased (hereinafter decedent's estate), Vita D'Ambrosio, Executrix (hereinafter the executrix), petitioned the Court to redetermine respondent's determination of an $842,391 deficiency in the Federal estate tax of decedent's estate. We must decide whether decedent's gross estate for Federal estate tax purposes includes the value...

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