Estate of Clara D. Baird, Deceased, Fleet Trust Company, William C. Baird, and Barbara B. Groetzinger, Co-Executors - Page 1

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                                 T.C. Memo. 1997-55                                   


                               UNITED STATES TAX COURT                                


          ESTATE OF CLARA D. BAIRD, DECEASED, FLEET TRUST COMPANY, WILLIAM            
           C. BAIRD, AND BARBARA B. GROETZINGER, CO-EXECUTORS, Petitioner             
                   v. COMMISSIONER OF INTERNAL REVENUE, Respondent                    


               Docket No. 5726-95.               Filed January 30, 1997.              


               Sherman F. Levey, Peter Oddleifson, and Eric R. Paley,                 
          for petitioner.                                                             
               Theodore R. Leighton, Mark A. Ericson, and Theresa G.                  
          McQueeney, for respondent.                                                  


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               FOLEY, Judge:  By notice dated January 17, 1995, respondent            
          determined a deficiency in petitioner's estate tax of                       
          $118,709.31.  All section references are to the Internal Revenue