T.C. Memo. 1999-342
UNITED STATES TAX COURT
ESTATE OF SAM HOMER MARMADUKE, DECEASED, JOHN H. MARMADUKE,
INDEPENDENT EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17047-97. Filed October 14, 1999.
William R. Cousins III, Robert Don Collier, and Robert M.
Bolton, for petitioners.
Audrey M. Morris, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge: Respondent determined a deficiency of
$1,809,921 in the Federal estate tax of the Estate of Decedent
Sam Homer Marmaduke.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect as of September 7, 1993 (the
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