ESTATE OF ANDREWS v. COMMISSIONER

Docket No. 12465-79.

79 T.C. 938 (1982)

ESTATE OF WOODBURY G. ANDREWS, DECEASED, WOODBURY H. ANDREWS, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 29, 1982.


Attorney(s) appearing for the Case

Franz P. Jevne III, Michael S. Frost, and George R. A. Johnson, for the petitioner.

Jeffrey D. Lerner, for the respondent.


OPINION

WHITAKER, Judge:

Respondent determined a deficiency of $160,981.67 in the Federal estate tax of petitioner. The sole issue for decision is the date-of-death fair market value of shares of stock held by decedent in four closely held corporations. Since this case is largely factual, we have combined our findings of fact with our opinion.

Some of the facts have been stipulated and are so found. The parties have stipulated that Woodbury...

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