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ESTATE OF HEINOLD v. C. I. R.

No. 15317.

363 F.2d 329 (1966)

ESTATE of Matthew I. HEINOLD, Deceased, Virgil W. Heinold, Executor, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Seventh Circuit.

June 17, 1966.

Attorney(s) appearing for the Case

John L. Carey, Bruce R. Bancroft, South Bend, Ind., Delmar R. Hoeppner, Valparaiso, Ind., Edward J. Gray, South Bend, Ind., for petitioner.

Richard M. Roberts, Asst. Atty. Gen., Herbert Grossman, Atty., Tax Div., Lee A. Jackson, Gilbert E. Andrews, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before HASTINGS, Chief Judge and KNOCH and CASTLE, Circuit Judges.

KNOCH, Circuit Judge.

The petitioner, Estate of Matthew I. Heinold, deceased, Virgil W. Heinold, Executor, seeks review of a decision of the Tax Court of the United States finding a deficiency in estate taxes, with specific reference to two disputed issues decided adversely to the petitioner.

The Tax Court held that the fair market value of 25,000 shares of stock owned by decedent at his death was $8 per share rather than the value of approximately half that...

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