T.C. Memo. 1997-55
UNITED STATES TAX COURT
ESTATE OF CLARA D. BAIRD, DECEASED, FLEET TRUST COMPANY, WILLIAM
C. BAIRD, AND BARBARA B. GROETZINGER, CO-EXECUTORS, Petitioner
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5726-95. Filed January 30, 1997.
Sherman F. Levey, Peter Oddleifson, and Eric R. Paley,
for petitioner.
Theodore R. Leighton, Mark A. Ericson, and Theresa G.
McQueeney, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: By notice dated January 17, 1995, respondent
determined a deficiency in petitioner's estate tax of
$118,709.31. All section references are to the Internal Revenue
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