ESTATE OF PUDIM v. COMMISSIONER

Docket No. 425-76.

44 T.C.M. 1425 (1982)

T.C. Memo. 1982-606

Estate of John Pudim, Jr., Deceased, Edward Pudim, Administrator v. Commissioner.

United States Tax Court.

Filed October 18, 1982.


Attorney(s) appearing for the Case

Edward Pudim (administrator), for the petitioner. Frank W. Louis and David N. Brodsky, for the respondent.


Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:*

Respondent determined a deficiency of $36,046.71 in petitioner's Federal estate tax. After concessions, the issues for decision are:

(1) Whether the decedent's one-half undivided interests in three parcels of real property and certain personal property should be valued at one-half the fair market value of such properties or at some discount thereto.

(2)...

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