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.
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