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ESTATE OF PATTISON v. COMMISSIONER

Docket No. 26805-87.

60 T.C.M. 471 (1990)

T.C. Memo. 1990-428

Estate of Evelyn Wendt Pattison, Deceased, Marie D. Pattison, Executrix v. Commissioner.

United States Tax Court.

Filed August 8, 1990.

Attorney(s) appearing for the Case

George W. Connelly, Jr., 1200 Smith St., Houston, Tex., and Victoria J. Sherlock, 909 Fannin, Houston, Tex., for the petitioner. Phillip A. Pillar, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

Respondent determined a deficiency of $730,098 in the decedent's Federal estate tax. After concessions,1 the sole issue for decision is the fair market value of two parcels of unimproved land in Waller County, Texas, on the date of decedent's death.

Findings of Fact

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

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