ESTATE OF McGILL v. COMMISSIONER

Docket No. 21876-81.

48 T.C.M. 239 (1984)

T.C. Memo. 1984-292

Estate of Madeline F. McGill, Deceased, J.R. Hanna, Personal Representative v. Commissioner.

United States Tax Court.

Filed June 4, 1984.


Attorney(s) appearing for the Case

L. William Schmidt, Jr., John A. Wallace, Michael C. Russ, L. Joseph Loveland, and Peter J. Genz for the petitioner. Benjamin A deLuna, for the respondent.


Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined a deficiency of $5,595,018 in the Federal estate tax of petitioner. After concessions by the parties, the sole issue for decision is the date-of-death value of voting trust certificates representing decedent's beneficial interest in stock of a closely-held corporation.

Findings of Fact

Some of the facts have been stipulated and are so found.

Madeline F....

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