SUPPLEMENTAL MEMORANDUM OPINION
HAMBLEN, Judge:
This matter is before the Court on remand from the U.S. Court of Appeals for the Fifth Circuit. Estate of McLendon v. Commissioner [96-1 USTC ¶ 60,220], 77 F.3d 477 (5th Cir. 1995), revg. in part and remanding without published opinion [Dec. 49,318(M)]
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