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ESTATE OF HOFFMAN v. COMMISSIONER

Docket No. 8632-98.

81 T.C.M. 1588 (2001)

T.C. Memo. 2001-109

Estate of Marcia P. Hoffman, Deceased, Elisabeth Hoffman, Personal Representative v. Commissioner.

United States Tax Court.

Filed May 9, 2001.

Attorney(s) appearing for the Case

Joseph D. Edwards and Albert P. Silva, for the petitioner.

Michael A. Pesavento, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge:

Respondent determined a deficiency of $930,864 in the Federal estate tax of the estate of decedent Marcia P. Hoffman. After concessions,1 the issues for decisions are: (1) Whether guaranteed distributions under a marital settlement agreement survived decedent's death and are includable in her gross estate under section 2031...

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