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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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Last modified: May 25, 2011