Docket No. 7156-94.

72 T.C.M. 488 (1996)

T.C. Memo. 1996-395

Estate of James Barudin, Deceased, Muriel B. Clarke, Executrix v. Commissioner.

United States Tax Court.

Filed August 26, 1996.

Attorney(s) appearing for the Case

Jeffrey M. Novick, Garden City, N.Y., Richard S. Kestenbaum, and Bernard S. Mark, for the petitioner. Dante D. Lucas and Pamela L. Cohen, for the respondent.


SWIFT, Judge:

Respondent determined a deficiency of $163,751 in the Federal estate tax of the Estate of James Barudin (decedent).

Unless otherwise indicated, all section references are to the Internal Revenue Code as of December 31, 1989, the date of decedent's death.

After settlement of some issues, the only issue for decision is the proper date-of-death value of decedent's ownership unit in a partnership...

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