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ESTATE OF DUILIO COSTANZA v. COMMISSIONER

Docket No. 16059-97.

81 T.C.M. 1693 (2001)

T.C. Memo. 2001-128

Estate of Duilio Costanza, Deceased, Michael J. Costanza, Executor, v. Commissioner.

United States Tax Court.

Filed June 4, 2001.

Attorney(s) appearing for the Case

Charles L. McKelvie and Rita A. Baird, for the petitioner.

Robert S. Bloink and Meso T. Hammoud, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

The Estate of Duilio Costanza, Deceased, Michael J. Costanza, Executor, petitioned the Court to redetermine respondent's determination of a $297,062 deficiency in its Federal estate tax. Following concessions, we must decide whether the gross estate of Duilio Costanza (decedent) includes, or whether decedent made a taxable gift of, any or all of the value of certain real estate conveyed by his trust in...

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