Estate of Gallagher

Estate of Gallagher

It’s déjà vu all over again


When reading the U.S. Tax Court decision in Gallagher v. Commissioner,1 I was reminded of the 1993 comedy “Groundhog Day.” As you may recall, Phil Connors (played by Bill Murray) is a TV weatherman who finds himself repeating the same unpleasant day over and over again when covering the annual Groundhog Day event in P

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