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ESTATE OF LETTS v. COMMISSIONER

Docket No. 8539-95.

109 T.C. 290 (1997)

ESTATE OF MILDRED GERALDINE LETTS, DECEASED, JAMES P. LETTS III AND JOANNE L. MAGBEE, COEXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 24, 1997.

Attorney(s) appearing for the Case

Timothy J. Peaden, John C. Sawyer, and Michelle M. Henkel, for petitioner.

David Delduco and Charles P. Hanfman, for respondent.

OPINION

COLVIN, Judge:

Respondent determined that petitioner is liable for a $461,601 deficiency in Federal estate tax. The issue for decision is whether, because of the duty of consistency, decedent's estate includes the value of property that decedent's husband left to her. We hold that it does.1

Unless otherwise indicated, section references are to the Internal Revenue Code. Rule references are to the Tax Court...

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