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Richard B Covey
New York New York
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allocated alternative minimum tax amended amount apply assets beneficiary benefit buy-sell agreement capital gain cash charitable claim closely-held Code common stock community property corporation Covey dece decedent decedent's death December 31 determined disclaimer dividend effect election estate tax return estate tax value executor extent fair market value federal estate tax fiduciary filed formula fractional share funding Gift and Income gift tax grantor holding company I.R.C. section included income tax Internal Revenue Service issue itemized deductions Letter Ruling marital deduction ment Miami minimum worth nonmarital ordinary income paid partner partnership interest partnership liabilities payable payment percent person Plan power of appointment preferred stock prior problem qualified real property received redemption Regulation section respect result Revenue Ruling risk section 303 section 691 income Service shareholders shelter spouse's statute Suisman surviving spouse Tax Court Tax Reform Act taxpayer tion transfer trust property valuation