T.C. Memo. 1997-13 UNITED STATES TAX COURT ESTATE OF CHARLES BAXTER SOUTHERN, SR., DECEASED, FIRST AMERICAN TRUST COMPANY, N.A., CO-EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2249-95. Filed January 7, 1997. Allan J. Wade, for petitioner. E. Ford Holman, Jr., for respondent. MEMORANDUM OPINION K�RNER, Judge: This case is before the Court on petitioner's motion for summary judgment and respondent's motion for partial summary judgment under Rule 121.1 There is no 1 All statutory 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, except as otherwise noted.Page: 1 2 3 4 5 6 7 8 9 Next
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