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ESTATE OF MURPHY v. COMMISSIONER

Docket Nos. 32730-86, 32731-86.

60 T.C.M. 645 (1990)

T.C. Memo. 1990-472

Estate of Elizabeth B. Murphy, Deceased, First Bank (National Association)-Duluth and Richard R. Burns, as Co-Personal Representatives and Co-Trustees under Agreement with Elizabeth B. Murphy, Dated February 3, 1981 v. Commissioner.

United States Tax Court.

Filed August 30, 1990.

Attorney(s) appearing for the Case

Raymond L. Erickson and Richard R. Burns, 1000 First Bank Place, Duluth, Minn., for the petitioner. Jack Forsberg, for the respondent.

Memorandum Findings of Fact and Opinion

COLVIN, Judge:

Respondent determined a deficiency in decedent's Federal estate tax of $8,133,984 and a deficiency in gift tax for the calendar year 1982 of $10,248,403.

Both deficiency notices result from a dispute concerning the valuation of a 51.41 percent block of stock over which the decedent had a general power of appointment during her life. The gift tax deficiency notice results from the decedent's gift...

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