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ESTATE OF PILLSBURY v. COMMISSIONER

Docket No. 4302-90.

64 T.C.M. 284 (1992)

T.C. Memo. 1992-425.

Estate of Eleanor O. Pillsbury, Deceased, San Diego Trust & Savings Bank, Executor and Trustee, under Eleanor O. Pillsbury 1984 Trust v. Commissioner.

United States Tax Court.

Filed July 27, 1992.

Attorney(s) appearing for the Case

Laurence L. Pillsbury, 7730 Herschel Ave., La Jolla, Calif., and Robert K. Smith, 1200 Prospect St., La Jolla, Calif., for the petitioner. Thomas A. Dombrowski, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined a deficiency of $150,729 in the Federal estate tax of the estate of Eleanor O. Pillsbury, deceased. After concessions, the issues remaining for decision are: (1) Whether the value of decedent's undivided 77-percent interest in real property is less than 77 percent of the value of a 100-percent interest in the property, (2) whether the value of decedent's undivided 77-percent interest...

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