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ESTATE OF Di FIORE v. COMMISSIONER

Docket No. 3340-85.

54 T.C.M. 1168 (1987)

T.C. Memo. 1987-588

Estate of Dominic Di Fiore, Deceased, Richard Di Fiore, Executor v. Commissioner.

United States Tax Court.

Filed November 25, 1987.

Attorney(s) appearing for the Case

Roger E. Grove, for the petitioner. Thomas M. Rohall, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent determined a deficiency, against the Estate of Dominic Di Fiore, in the amount of $196,225.59, and an addition to tax, pursuant to section 6651(a)(1),1 in the amount of $103,158.54. After concessions, the issues remaining for our consideration are: (1) Whether petitioner is entitled to section 2032A special use valuation...

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