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ESTATE OF GALLO v. COMMISSIONER

Docket No. 24465-82.

50 T.C.M. 470 (1985)

T.C. Memo. 1985-363

Estate of Mark S. Gallo, R. J. Gallo, Administrator v. Commissioner.

United States Tax Court.

Filed July 22, 1985.

Attorney(s) appearing for the Case

M. Bernard Aidinoff, Philip L. Graham, Jr., Henry Christensen III, Florence A. Davis and Dean C. Berry, Sullivan & Cromwell, 125 Broad St., N. Y., N. Y. and William D. McKee and Paul J. Sax, Orrick, Herrington & Sutcliffe, 600 Montgomery St., San Francisco, Calif., for the petitioner. Alan S. Beinhorn, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined a deficiency of $347,871 in petitioner's Federal estate tax. The issue for decision is the date-of-death value of a certain minority interest in the common stock of a closely held corporation.

Findings of Fact

Some of the facts have been stipulated and are so found. The stipulation of facts and exhibits attached...

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