FIORITO v. COMMISSIONER

Docket No. 68409.

33 T.C. 440 (1959)

ANGELA FIORITO, EXECUTRIX OF THE ESTATE OF NICOLO FIORITO, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 30, 1959.


Attorney(s) appearing for the Case

Joseph A. Barto, Esq., for the petitioner.

Norman H. McNeil, Esq., for the respondent.


OPINION.

DRENNEN, Judge:

Respondent determined a deficiency in estate tax due from the estate of Nicolo Fiorito in the amount of $16,523.62.

The only issue left for us to decide is whether respondent erred in determining the value of decedent's interest in a partnership known as N. Fiorito Company to be his pro rata share of the fair market value of the partnership net assets as of the date of decedent's death rather than the option price...

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