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response in opposition to petitioner's motion. Both petitioner
and respondent submitted memoranda in support of their positions.
Respondent determined a deficiency in petitioner's Federal
estate tax of $14,107,060. The deficiency was due primarily to
respondent's increased valuation of decedent's stock in his
closely held corporations, as well as respondent's disallowance
of certain deductions for claims against the estate. The parties
have resolved the valuation issues.
The disallowed deductions relate to various claims on dece-
dent's closely held stock. Specifically, Ann Goss, decedent's
former wife, holds a claim to the income from the stock for her
life, and his three children hold a claim to the remainder
interest in the stock. Respondent has conceded that the estate
is entitled to a deduction for Ann Goss' interest in the stock.
Therefore, the issue for decision is whether petitioner is
entitled to deduct the value of the decedent's children's
remainder interest in the stock as a claim against the estate
under section 2053(a)(3).
We may grant a motion for summary judgment under Rule 121
"if the pleadings, answers to interrogatories, depositions,
admissions, and any other acceptable materials, together with the
affidavits, if any, show that there is no genuine issue as to any
1(...continued)
death, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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