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MILLER v. COMMISSIONER

Docket Nos. 23465-93, 23558-93.

71 T.C.M. 1674 (1996)

T.C. Memo. 1996-3

Elizabeth B. Miller v. Commissioner. Robert N. Miller III v. Commissioner.

United States Tax Court.

Filed January 11, 1996.

Attorney(s) appearing for the Case

Ward R. Nyhus, Jr., Los Angeles, Calif., for the petitioners. Steven M. Roth, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge:

Respondent determined the following deficiencies under section 2501(a)1 in petitioners' Federal gift tax:

Petitioner                        Year2   Deficiency

Elizabeth B. Miller ...........   1989     $31,500
Robert N. Miller III3 .........   1989      31,500

The issues...

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