Estate of Rose B. Posner, Deceased, David B. Posner, Personal Representative - Page 1
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T.C. Memo. 2004-112
UNITED STATES TAX COURT
ESTATE OF ROSE B. POSNER, DECEASED, DAVID B. POSNER,
PERSONAL REPRESENTATIVE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12780-01. Filed May 10, 2004.
Mark T. Willen and Peter E. Keith, for petitioner.
C. Teddy Li, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge: Respondent determined a $1,114,795 Federal
estate tax deficiency with respect to the Estate of Rose B.
Posner (the estate). The parties have resolved all issues raised
in the notice of deficiency. The estate contends, however, that
it is entitled to a $2,909,000 estate tax refund because certain
marital trust property was erroneously included in the gross
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Last modified: May 25, 2011