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ESTATE OF WILSON v. COMMISSIONER

Docket Nos. 2167-62, 2168-62.

23 T.C.M. 87 (1964)

T.C. Memo. 1964-17

Estate of Arch Wilson, Deceased, Warner M. Wilson and Pauline W. Woodruff, Co-Executors v. Commissioner. Pauline G. Wilson v. Commissioner.

United States Tax Court.

Filed January 29, 1964.

Attorney(s) appearing for the Case

Eugene J. Brenner, for the petitioners. Leo A. McLaughlin, for the respondent.

Memorandum Findings of Fact and Opinion

ARUNDELL, Judge:

Respondent has determined a deficiency in gift taxes for the year 1958 in the amount of $14,237.43 against the donors Arch Wilson and his wife Pauline G. Wilson. Since the initiation of these proceedings, Arch Wilson has died and his executors have been substituted as petitioners.

The sole question is the fair market value of a 17.743 acre tract of land in the town of Cupertino, California...

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