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ESTATE OF KELLY v. COMMISSIONER

Docket No. 45283.

14 T.C.M. 476 (1955)

T.C. Memo. 1955-129

Estate of Eugene H. Kelly, Deceased, John C. Kelly, Eugene F. Kelly, and Arthur Lennon Kelly, Executors v. Commissioner.

United States Tax Court.

Filed May 20, 1955.

Attorney(s) appearing for the Case

Allen Whitfield, Esq., and G. O. Patterson, Esq., for the petitioner. Merl B. Peek, Esq., for the respondent.

Respondent determined a deficiency of $104,621.78 in estate tax of the petitioner.

The only issue here involved, other than questions to be determined under Rule 50, is the fair market value of 106 shares of stock of Journal-Tribune Publishing Company as of the applicable valuation date.

Memorandum Findings of Fact and Opinion

The stipulated facts are so found and are incorporated herein by reference.

Eugene H. Kelly died testate on May 16, 1948. The Federal Estate Tax Return of his estate was duly filed on August 16, 1949, the return being filed with, and the tax paid to, the collector of internal revenue at Des Moines, Iowa. The decedent's estate was valued as of the date of death of the decedent and the gross estate as reported in the...

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