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ESTATE OF PRELL v. COMMISSIONER

Docket No. 2577-64.

48 T.C. 67 (1967)

ESTATE OF CHARLES M. PRELL, SR., DECEASED, CHARLES M. PRELL, JR., AND HELEN M. PRELL, CO-EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 26, 1967.

Attorney(s) appearing for the Case

John E. Forrester and Ralph D. Kovanda, for the petitioner.

Erwin L. Stuller, for the respondent.

WITHEY, Judge:

An estate tax deficiency has been determined by respondent against petitioner in the amount of $220,932.93. The issues to be decided are (1) what is the correct valuation date for certain shares of stock which were assets of decedent's estate, (2) what was the fair market value thereof on one valuation date, (3) whether decedent transferred $8,240 to his son and daughter prior to his death, and (4) what is the proper attorney's fee allowance...

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