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ESTATE OF HARPER v. COMMISSIONER

Docket No. 19336-98.

83 T.C.M. 1641 (2002)

T.C. Memo. 2002-121

Estate of Morton B. Harper, Deceased, Michael A. Harper, Executor v. Commissioner.

United States Tax Court.

Filed May 15, 2002.

Attorney(s) appearing for the Case

Warren J. Kessler and Joan B. Kessler, for the petitioner.

Donna F. Herbert and Jonathan H. Sloat, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

NIMS, Judge.

Respondent determined, as a primary position, a Federal estate tax deficiency in the amount of $331,171 with respect to the estate of Morton B. Harper (the estate). In the alternative, respondent determined a Federal estate tax deficiency of $150,496 and a Federal gift tax deficiency of $180,675 for the 1994 calendar period. The principal issue for decision is the proper treatment for estate and gift tax...

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