T.C. Memo. 1997-119
UNITED STATES TAX COURT
LEE M. BENTLEY AND AMSOUTH BANK OF FLORIDA, (f.k.a. FIRST
NATIONAL BANK OF CLEARWATER), CO-TRUSTEES OF THE SEYMOUR C.
MICKLER TRUST, FBO LAURA M. BENTLEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
PATRICIA M. DAWSON AND AMSOUTH BANK OF FLORIDA,(f.k.a. FIRST
NATIONAL BANK OF CLEARWATER), CO-TRUSTEES OF THE SEYMOUR C.
MICKLER TRUST, FBO PATRICIA DAWSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 16067-95, 16070-95. Filed March 10, 1997.
David M. Boggs, for petitioners.
Stephen R. Takeuchi, for respondent.
MEMORANDUM OPINION
WRIGHT, Judge: The above cases were consolidated on
December 29, 1995. This matter is before the Court on
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