Estate of Ambrosina Blanche Lopes, deceased, James W. Lopes, Trustee - Page 1

                                 T.C. Memo. 1999-225                                  

                               UNITED STATES TAX COURT                                

               ESTATE OF AMBROSINA BLANCHE LOPES, DECEASED, JAMES W.                  
                            LOPES, TRUSTEE, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5012-98.                      Filed July 8, 1999.           

               Paul J. Barulich, for petitioner.                                      
               Marion T. Robus, for respondent.                                       

                                 MEMORANDUM OPINION                                   

               GERBER, Judge:  This case is before the Court on cross-                
          motions for partial summary judgment under Rule 121.1  Respondent           
          determined a deficiency of $4,210,985 in the Federal estate tax             

               1 All section 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,            
          unless otherwise indicated.                                                 

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