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Unless stated otherwise, section references are to the
Internal Revenue Code. Rule references are to the Tax Court
Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Decedent and His Family
Decedent was married to Jessie Glenn Reichardt (Mrs.
Reichardt). They had two children, Carolyn A. Reichardt Foose
(Carolyn Foose) and William D. Reichardt (William Reichardt).
Mrs. Reichardt died at age 77 on December 6, 1991. Decedent
lived at 214 Encino, Alamo Heights, San Antonio, Texas (214
Encino), when he died on August 21, 1994.
B. Mrs. Reichardt
1. Mrs. Reichardt's Inheritance
Mrs. Reichardt graduated from Rice University in Houston,
Texas. Her father died in 1971. Mrs. Reichardt handled her own
business affairs. Mrs. Reichardt inherited from her father an
undivided one-half interest in several parcels of real property
in Kleberg and Nueces Counties, Texas, and various securities.
Mrs. Reichardt's sister, Ruth Welch (Welch), inherited the other
one-half interest in the property.
Mrs. Reichardt's uncle, Jessie Dennett, died in 1973. Mrs.
Reichardt inherited from Jessie Dennett a one-half undivided
interest in real property in Kleberg County, Texas, and a one-
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