ESTATE OF BELL v. COMMISSIONER

Docket No. 12692-85.

54 T.C.M. 1123 (1987)

T.C. Memo. 1987-576

Estate of Norman L. Bell, Deceased, Shirley Bell, Independent Executrix v. Commissioner.

United States Tax Court.

Filed November 23, 1987.


Attorney(s) appearing for the Case

Donald D. DeGrasse, for the petitioner. Thomas G. Norman and David E. Whitcomb, for the respondent.


Memorandum Findings of Fact and Opinion

WILLIAMS, Judge:

The Commissioner determined a deficiency in petitioner's Federal estate tax in the amount of $1,194,949.31. The issue we must decide is the value for Federal estate tax purposes of shares of stock in a closely-held corporation. Our decision has turned on how poorly petitioner and respondent have carried their respective burdens of proof.

Respondent's determination of a deficiency in estate...

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