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ESTATE OF SMITH v. COMMISSIONER

Docket Nos. 7378-71, 5746-73.

63 T.C. 722 (1975)

ESTATE OF CHARLES A. SMITH, DECEASED, DONALD C. SMITH, EXECUTOR, ET AL., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ESTATE OF CHARLES A. SMITH, DECEASED, DONALD C. SMITH, ET AL., EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 27, 1975.

Attorney(s) appearing for the Case

George M. Zimmermann and Ralph J. Gregg, for the petitioner.

John D. Steele, Jr., for the respondent.

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $38,145.91 in petitioner's Federal estate tax (docket No. 7378-71) and a deficiency of $170,717.58 in petitioner's Federal income tax for the taxable period August 13, 1967, to July 31, 1968 (docket No. 5746-73).

The issues presented for decision are:

1. Whether the value of stock purchase warrants of Gulf & Western Industries, Inc., received by the Estate of Charles...

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