T.C. Memo. 2002-2
UNITED STATES TAX COURT
ESTATE OF DONNY DAVID DOSTER, DECEASED, JIMMY MACK DOSTER,
INDEPENDENT EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9411-00L. Filed January 4, 2002.
Walker Arenson and Robert A. Helms, for petitioner.
Carol B. Reeve, Marilyn S. Ames, and Gordon P. Sanz, for
respondent.
MEMORANDUM OPINION
FOLEY, Judge: The issues for decision are whether: (1)
Respondent’s reconsideration of his denial of the estate’s
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