SUPPLEMENTAL MEMORANDUM OPINION
PARR, Judge:
This case is before the Court on remand from the Court of Appeals for the Tenth Circuit. Estate of Sympson v. Commissioner, 54 F.3d 787, 75 AFTR 2d 95-2255, 95-1 USTC par. 50,276 (10th Cir. 1995), affg. in part and revg. in part without published opinion [Dec. 49,603(M)]
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