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ESTATE OF EDWARDS v. COMMISSIONER

Docket No. 10172-99.

82 T.C.M. 471 (2001)

T.C. Memo. 2001-229

Estate of Pattie Welder Edwards, Deceased, Oakes David Edwards, Jr., and Patricia Edwards Carson, Co-Executors v. Commissioner.

United States Tax Court.

Filed August 23, 2001.

Attorney(s) appearing for the Case

Terrell W. Dahlman and Frederick F. Rogers, Jr., for the petitioner. Gerald L. Brantley, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge:

Respondent determined a deficiency of $523,771 in the 1994 Federal estate tax of the estate of Pattie Welder Edwards (the estate). After concessions, the issue for decision is whether the ranch properties owned by decedent at her date of death were encumbered by oral options that extended the existing leases on the ranch properties and, if so, whether the oral options or the existing leases were a restriction...

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