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the bequest must have been made from property that is subject to
the U.S. estate tax.
The parties stipulated that the bequests were paid solely
out of funds and property located outside the United States. The
funds used to pay the bequests were, therefore, not subject to
the estate tax in the United States. Secs. 2101, 2103. We
conclude that the convention, as amended by the 1995 Protocol,
does not change the result from that under section 2106 in this
instance. Accordingly, we sustain respondent’s determination.
In reaching our holding herein, we have considered all
arguments made, and to the extent not mentioned above, we
conclude them to be moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011