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ESTATE OF LIONEL WEIL v. COMMISSIONER

Docket No. 36237.

22 T.C. 1267 (1954)

ESTATE OF LIONEL WEIL, DECEASED, HENRY WEIL AND WACHOVIA BANK & TRUST COMPANY, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 27, 1954.

Attorney(s) appearing for the Case

W. Frank Taylor, Esq., for the petitioners.

R. V. Bradbury, Jr., Esq., for the respondent.

OPINION.

ARUNDELL, Judge:

Respondent determined a deficiency of $68,556.19 in the estate tax of the decedent, Lionel Weil. The sole question to be decided is whether the value of decedent's interest in a partnership for the purpose of computing the gross estate is limited to the amount prescribed by certain agreements previously entered into by decedent and his partners.

All of the facts were stipulated and they are so found and incorporated...

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