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Background
In a memorandum of law in support of its objection to
respondent’s motion for partial summary judgment, the estate
states that it agrees, with limited exceptions, to the statement
of facts contained in respondent’s memorandum of law in support
of the motion for partial summary judgment. The following
factual summary is based on the undisputed portions of
respondent’s statement of facts, the parties’ stipulations, the
estate’s admissions, the pleadings, and an affidavit produced by
respondent with accompanying documents, to which the estate has
not objected. This factual summary is set forth solely for
purposes of deciding the motion for partial summary judgment; it
does not constitute findings of fact. See Sundstrand Corp. v.
Commissioner, 98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th
Cir. 1994).
Decedent
Decedent was president and primary stockholder of National
Fruit Product Co., Inc. (National Fruit), a closely held Virginia
corporation engaged in the manufacture of applesauce, apple
juice, and other fruit products. On July 29, 1993, decedent
died. His domicile at death was in Winchester, Virginia. When
the petition was filed, the executor’s legal residence was in
Winchester, Virginia.
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Last modified: May 25, 2011