Estate of Robert E. Sympson, Deceased, Elizabeth C. Sympson Personal Representative and Elizabeth C. Sympson - Page 1

                                 T.C. Memo. 1996-352                                  


                               UNITED STATES TAX COURT                                


             ESTATE OF ROBERT E. SYMPSON, DECEASED, ELIZABETH C. SYMPSON              
          PERSONAL REPRESENTATIVE AND ELIZABETH C. SYMPSON, Petitioners v.            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent*                     


               Docket No. 971-92.                      Filed July 31, 1996.           


               Bruce Hallmark, for petitioners.                                       
               Steven B. Bass, for respondent.                                        


                           SUPPLEMENTAL MEMORANDUM OPINION                            
               PARR, Judge:  This case is before the Court on remand from             
          the Court of Appeals for the Tenth Circuit.  Estate of Sympson v.           
          Commissioner, 54 F.3d 787, 75 AFTR 2d 95-2255, 95-1 USTC par.               
          50,276 (10th Cir. 1995), affg. in part and revg. in part without            

               *  This opinion supplements our opinion in Estate of Sympson           
          v. Commissioner, T.C. Memo. 1994-2.                                         




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