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ESTATE OF CLACK v. COMMISSIONER

Docket No. 12557-91.

106 T.C. 131 (1996)

ESTATE OF WILLIS EDWARD CLACK, DECEASED, MARSHALL & ILSLEY TRUST COMPANY, CO-PERSONAL REPRESENTATIVE, AND RICHARD E. CLACK, CO-PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 29, 1996.

Attorney(s) appearing for the Case

Robert L. Kamholz, Jr., and John M. Byers, for petitioner.

Michael J. Calabrese, for respondent.

WELLS, Judge:*

Respondent determined a deficiency of $2,284,008 in the Federal estate tax of the Estate of Willis Edward Clack (estate). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect on the date of death of Willis Edward Clack (decedent), and all Rule references are to the Tax Court Rules of Practice and Procedure. The issue to be decided in this opinion is whether the interest of...

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