ESTATE OF BRUCE v. COMMISSIONER

Docket Nos. 27311-90, 27729-90.

65 T.C.M. 2848 (1993)

T.C. Memo. 1993-244

Estate of Shirley A. Bruce, Deceased, Patrick M. Bruce, Personal Representative v. Commissioner. Shirley A. Bruce, Deceased, Donor and Estate of Shirley A. Bruce, Deceased, Patrick M. Bruce, Executor and Personal Representative v. Commissioner.

United States Tax Court.

Filed June 1, 1993.


Attorney(s) appearing for the Case

Leo S. Meysing, 823 Pittock Block, Portland, Ore., for the petitioner. Christine V. Olsen, for the respondent.


Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined a deficiency of $65,015 in decedent's Federal gift tax for 1982, and a deficiency in petitioner's Federal estate tax of $240,271.

After concessions by the parties, including resolution of the estate tax deficiency, the issue for decision is whether, as a result of a sale and redemption of the stock of a closely held corporation on or about July 1, 1982, Shirley A. Bruce made...

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