ESTATE OF RATCLIFFE v. COMMISSIONER

Docket No. 3464-90.

63 T.C.M. 3068 (1992)

T.C. Memo. 1992-305

Estate of Hattie Starke Ratcliffe, Deceased, Louis G. Ratcliffe, Jr., Executor v. Commissioner.

United States Tax Court.

Filed May 27, 1992.


Attorney(s) appearing for the Case

Charles E. Johnson, 301 College St., Charlotte, N.C., and Neill G. McBryde, 227 N. Tryon St., Charlotte, N.C., for the petitioner. James E. Gray, for the respondent.


Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined a deficiency of $997,062 in decedent's Federal estate tax and a $214,733 valuation understatement addition to tax under section 6660. After concessions by the parties, the issues for decision are the values of three parcels of real estate in Charlotte, North Carolina, on the date of decedent's death. Respondent conceded the section 6660 addition to tax.

All section references...

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