T.C. Memo. 1996-352
UNITED STATES TAX COURT
ESTATE OF ROBERT E. SYMPSON, DECEASED, ELIZABETH C. SYMPSON
PERSONAL REPRESENTATIVE AND ELIZABETH C. SYMPSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 971-92. Filed July 31, 1996.
Bruce Hallmark, for petitioners.
Steven B. Bass, for respondent.
SUPPLEMENTAL MEMORANDUM OPINION
PARR, Judge: This case is before the Court on remand from
the Court of Appeals for the Tenth Circuit. Estate of Sympson v.
Commissioner, 54 F.3d 787, 75 AFTR 2d 95-2255, 95-1 USTC par.
50,276 (10th Cir. 1995), affg. in part and revg. in part without
* This opinion supplements our opinion in Estate of Sympson
v. Commissioner, T.C. Memo. 1994-2.
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