Estate of Rosa B. Neff, Deceased, Chris Hunt, Executor - Page 1

                                 T.C. Memo. 1997-186                                  

                               UNITED STATES TAX COURT                                

                          ESTATE OF ROSA B. NEFF, DECEASED,                           
                        CHRIS HUNT, EXECUTOR, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 1426-95.                    Filed April 21, 1997.           

               Vernon D. Hyde, for petitioner.                                        
               Elizabeth Downs, for respondent.                                       

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               VASQUEZ, Judge:  Respondent determined a deficiency in                 
          petitioner's Federal estate tax in the amount of $61,381.  All              
          section references are to the Internal Revenue Code in effect as            
          of the date of decedent's death, and all Rule references are to             
          the Tax Court Rules of Practice and Procedure.                              

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