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ESTATE OF STEWART v. COMMISSIONER

Docket Nos. 5520-05, 5521-05.

92 T.C.M. 357 (2006)

T.C. Memo. 2006-225

Estate of Margot Stewart, Deceased, Brandon Stewart, Executor, Petitioner v. Commissioner. Estate of Margot Stewart, Deceased, Donor, Brandon Stewart, Executor, Petitioner v. Commissioner.

United States Tax Court.

October 24, 2006.

Attorney(s) appearing for the Case

Kirk H. O'Ferrall, Kathleen M. Citera, and Robert Callagy (specially recognized), for petitioners.

Shawna A. Early and Lydia A. Branche, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

The issues for decision are whether decedent made a completed gift of a 49-percent interest in real property, whether the value of that property should be included in decedent's estate pursuant to section 2036,1 and whether decedent's estate is entitled to deductions relating to property taxes and claims against the estate.

FINDINGS OF FACT

On July 10, 1989...

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