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ESTATE OF STRANGI v. COMMISSIONER

Docket No. 4102-99.

85 T.C.M. 1331 (2003)

T.C. Memo. 2003-145

Estate of Albert Strangi, Deceased, Rosalie Gulig, Independent Executrix v. Commissioner.

United States Tax Court.

Filed May 20, 2003.

Attorney(s) appearing for the Case

Norman A. Lofgren, G. Tomas Rhodus, and Michael C. Kelsheimer, for the petitioner.

Gerald L. Brantley, Lillian D. Brigman, Janice B. Geier, and John D. MacEachen, for the respondent.

SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge:

This matter is before the Court on remand from the Court of Appeals for the Fifth Circuit for further consideration consistent with its opinion in Estate of Strangi v. Commissioner [2002-2 USTC ¶ 60,441], 293 F.3d 279 (5th Cir. 2002) (Strangi II), affg. in part and revg. and remanding in part [Dec. 54,135] 115 T.C. 478...

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