Estate of Willis Edward Clack, Deceased, Marshall & Ilsley Trust Company, Co-Personal Representative, and Richard E. Clack, Co-Personal Representative - Page 73

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          that we will find the statute ambiguous and, if so, that both the           
          position we take today and the position we today abandon are                
          reasonable interpretations?  If there is no such risk, and I                
          believe that there is not, we should say so.  As I have said, we            
          are a court of national jurisdiction with expertise in the area             
          of Federal taxes.  What we say means something; it makes a                  
          difference.  We should explain ourselves, and strive to achieve             
          the right result.                                                           
               PARKER, J., agrees with this dissent.                                  

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