Estate of James G. Frazier - Page 9




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               Based upon our review of California State law, we conclude              
          that FNF's holdover created a new tenancy.  Accordingly, FNF's               
          original tenancy expired on December 31, 1992.  At the expiration            
          of the original tenancy, FNF's statutory right to remove its                 
          trade fixtures under section 1019 of the California Civil Code               
          expired.  Therefore, at the time of decedent's death, the trade              
          fixtures belonged to decedent and were includable in decedent's              
          gross estate under section 2033.                                             
               To reflect the foregoing,                                               
                                                   Decision will be entered            
                                              under Rule 155.                          




























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