T.C. Memo. 1997-443
UNITED STATES TAX COURT
ESTATE OF ARTHUR C. EDWARDS, DECEASED, KENNETH EDWARDS, EDWARD
EDWARDS AND JAMES EDWARDS, AS TRUSTEES OF THE ARTHUR C. EDWARDS
SETTLEMENT TRUST, PERSONAL REPRESENTATIVE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8214-93. Filed September 29, 1997.
Owen G. Fiore and Glenn M. Alperstein, for petitioner.
Debra Lynn Reale and S. Katy Lin, for respondent.
MEMORANDUM OPINION
FAY, Judge: This case is before us on petitioner's motion
for summary judgment pursuant to Rule 121.1 Respondent filed a
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect as of the date of decedent’s
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