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ESTATE OF CLOUTIER v. COMMISSIONER

Docket No. 8905-94.

71 T.C.M. 2001 (1996)

T.C. Memo. 1996-49

Estate of Joseph R. Cloutier, Joseph A. Cloutier, Fiduciary v. Commissioner.

United States Tax Court.

Filed February 13, 1996.

Attorney(s) appearing for the Case

Jon F. Spadorcia, S. Douglas Trolson, and Robert J. Milford, Indianapolis, Ind., for the petitioner. Russell D. Pinkerton, for the respondent.

MEMORANDUM OPINION

LARO, Judge:

The Estate of Joseph R. Cloutier, Joseph A. Cloutier, Fiduciary, petitioned the Court to redetermine respondent's determination of a $1,212,230 deficiency in the Federal estate tax of the Estate. Following concessions, we must decide whether a discount for lack of marketability applies to the stipulated value of stock owned by the Decedent at the time of his death, and, if so, the amount of this discount.

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