T.C. Memo. 1996-426
UNITED STATES TAX COURT
ESTATE OF HELEN G. WILLIAMSON, DECEASED,
DOUGLAS F. WOODS, EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20857-94. Filed September 19, 1996.
Richard J. Sideman and Wendy Abkin, for petitioner.
Elizabeth L. Groenewegen and Rebecca T. Hill, for
respondent.
MEMORANDUM OPINION
K�RNER, Judge: This case is before the Court on
petitioner's motion for partial summary judgment under Rule 121.
All statutory references are to the Internal Revenue Code in
effect as of the date of decedent's death, and all Rule
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