T.C. Memo. 2001-303
UNITED STATES TAX COURT
ESTATE OF ALGERINE ALLEN SMITH, DECEASED, JAMES ALLEN SMITH,
EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 19200-94. Filed November 21, 2001.
Harold A. Chamberlain and Michael C. Riddle, for petitioner.
R. Scott Shieldes, for respondent.
SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: This case is before the Court on remand from
the Court of Appeals for the Fifth Circuit for further
consideration consistent with its opinion in Estate of Smith v.
*This Memorandum Opinion supplements our Opinion in Estate
of Smith v. Commissioner, 108 T.C. 412 (1997), supplemented by
110 T.C. 12 (1998), revd., vacated, and remanded 198 F.3d 515
(5th Cir. 1999).
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