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ESTATE OF SOUTHERN v. COMMISSIONER

Docket No. 2249-95.

73 T.C.M. 1690 (1997)

T.C. Memo. 1997-13

Estate of Charles Baxter Southern, Sr., Deceased, First American Trust Company, N.A., Co-Executor v. Commissioner.

United States Tax Court.

Filed January 7, 1997.

Attorney(s) appearing for the Case

Allan J. Wade, Memphis, Tenn., for the petitioner. E. Ford Holman, Jr., for the respondent.

MEMORANDUM OPINION

KORNER, Judge:

This case is before the Court on petitioner's motion for summary judgment and respondent's motion for partial summary judgment under Rule 121.1 There is no dispute as to any material facts. Hearing and argument of the motions was held on April 22, 1996, in Memphis, Tennessee.

Charles Baxter Southern, Sr. (decedent), died on March 14, 1991, and was survived by his spouse, Dorothy I. Southern...

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