T.C. Memo. 1998-428
UNITED STATES TAX COURT
ESTATE OF MARIE S. HUBBERD, DECEASED, JOHN B.
McNAMARA, JR., AND CLAYBORNE L. NETTLESHIP,
CO-INDEPENDENT EXECUTORS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1941-98. Filed December 7, 1998.
Kevin P. Kennedy, for petitioner.
Deborah H. Delgado, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is before the Court
on petitioner's Motion for Partial Summary Judgment. The issue
for decision is whether a transfer made prior to the decedent's
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