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We are “not compelled to believe evidence which to it seems
improbable, or to accept as true uncorroborated evidence of
interested witnesses even though uncontradicted.” Marcella v.
Commissioner, 222 F.2d 878, 883 (8th Cir. 1955), affg. a
Memorandum Opinion of this Court. We hold that the property was
not owned by a partnership between the decedent and Joseph S.
Maniglia and that the Fam-Trust, Joseph S. Maniglia as trustee
and the decedent as sole beneficiary, owned the property at the
decedent’s death. Accordingly, respondent properly included the
entire value of the property in the decedent’s gross estate.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011