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ESTATE OF BONGARD v. COMMISSIONER

Docket No. 6141-03.

124 T.C. 95 (2005)

124 T.C. No. 8

ESTATE OF WAYNE C. BONGARD, DECEASED, JAMES A. BERNARDS, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 15, 2005.

Attorney(s) appearing for the Case

John W. Porter and Stephanie Loomis-Price, for petitioner.

Lillian D. Brigman and R. Scott Shieldes, for respondent.

GOEKE, Judge:

Respondent determined a $52,878,785 Federal estate tax deficiency against the Estate of Wayne C. Bongard (the estate). After concessions and stipulations, two issues remain for decision: First, whether the shares of Empak, Inc. (Empak), decedent transferred to WCB Holdings, LLC. (WCB Holdings), are included in his gross estate pursuant to sections 2035(a)1 and 2036(a) and (b); and second, whether the WCB Holdings membership...

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