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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