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ESTATE OF TOBIAS v. COMMISSIONER

Docket Nos. 19756-97, 19757-97.

81 T.C.M. 1163 (2001)

T.C. Memo. 2001-37

Estate of James R. Tobias, Deceased, V. Pauline Tobias, Executrix, and Verna P. Tobias, Surviving Spouse v. Commissioner. Darwin R. Tobias, Sr., and Shirley I. Tobias v. Commissioner.

United States Tax Court.

Filed February 14, 2001.

Attorney(s) appearing for the Case

John B. Consevage, for the petitioners in Docket No. 19756-97.

John S. Kundrat, for the petitioners in Docket No. 19757-97.

Joseph M. Abele and David A. Breen, for the respondent.

MEMORANDUM OPINION

WHALEN, Judge:

These consolidated cases are before the Court to decide the motion for summary judgment filed by the Estate of James R. Tobias and Ms. V. Pauline Tobias, the cross-motion for summary judgment filed by Mr. Darwin R. Tobias, Sr., and Ms. Shirley I. Tobias, and the cross-motion for summary judgment filed by respondent. The principal issues for decision in these cases involve the allocation of income pursuant to section 704...

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