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ESTATE OF SCHROEDER v. COMMISSIONER

Docket No. 19381.

13 T.C. 259 (1949)

ESTATE OF LILLIAN MAY SCHROEDER, DECEASED, CITY BANK FARMERS TRUST COMPANY, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated August 24, 1949.

Attorney(s) appearing for the Case

Herbert P. Polk, Esq., for the petitioner.

Stephen P. Cadden, Esq., for the respondent.

This proceeding has been instituted for the purpose of testing the correctness of the respondent's determination of a deficiency in estate tax in the amount of $4,327.05.

The petition raises two issues: (1) The fair market value of the capital stock of the Heberlein Patent Corporation, and (2) the right of the petitioner to treat the sum of $8,460 as previously taxed property.

FINDINGS OF FACT.

Petitioner is a corporation, organized and existing...

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