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to the other". Mrs. Marcus also was leery of becoming involved
in "local arguments" over how the property should be handled.
Mrs. Marcus and her sisters decided to resolve their
conflict by entering into an agreement entitled Deed of Family
Arrangement (the arrangement) on August 16, 1980. The
arrangement provided that the heirs, defined as Mrs. Marcus'
sisters, agreed to pay Mrs. Marcus a portion of the estate (one-
third of the net proceeds) when and as it was liquidated. In
return, Mrs. Marcus waived, disclaimed, forfeited, and forwent
any interest she might have had in the property.
Pursuant to the arrangement, Mrs. Marcus received $37,898 in
1990 from the sale of some of the apartments in Trieste, Italy.
Mrs. Marcus was not informed of the particulars of the sales;
i.e., sale price or number of units sold. The value of the
property at the date of her mother's death in 1970, at Mrs.
Marcus' stepfather's death in 1980, and when she signed the
arrangement was unknown to Mrs. Marcus. Petitioners did not
include the $37,898 in gross income on their 1990 Federal income
tax return.
Attorney's Fees
Mr. Marcus worked as an obstetrician/gynecologist for the
Marcus and Staglieno Medical Corp. (the corporation) in 1990. He
was president of the corporation and wrote checks on its behalf.
He periodically paid attorneys to defend him in lawsuits brought
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