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ESTATE OF O'CONNELL v. COMMISSIONER

Docket No. 6907-76.

37 T.C.M. 822 (1978)

T.C. Memo. 1978-191

Estate of J.E. O'Connell, James O'Connell, Executor v. Commissioner.

United States Tax Court.

Filed May 25, 1978.

Attorney(s) appearing for the Case

John R. Kline, 555 Fuller Ave., Helena, Mont., for the petitioner. Craig D. Platz, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined a deficiency in the Federal estate tax of the Estate of J.E. O'Connell in the amount of $5,782,238.63.

Concessions have been made by the parties. The two issues remaining for decision are: (1) the fair market value of decedent's 400 shares of R.V. Ranch Company stock on April 8, 1973, and (2) the fair market value of decedent's 34,423.5 shares of Capri, Inc., common stock...

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