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ESTATE OF FLEMING v. COMMISSIONER

Docket No. 22462-95.

74 T.C.M. 1049 (1997)

T.C. Memo. 1997-484

Estate of Thomas A. Fleming, Deceased, Cathy J. Hirt, Independent Successor Executrix v. Commissioner.

United States Tax Court.

Filed October 27, 1997.

Attorney(s) appearing for the Case

William R. Cousins III, Dallas, Tex., James R. Dobbs, Jr., Robert D. Collier, and Robert M. Bolton, for the petitioner. John R. Hunter, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge:

Respondent determined a deficiency of $512,881 in petitioner's Federal estate tax. The sole issue remaining for decision is the fair market value of the stock interest in a closely held corporation that was owned by Thomas A. Fleming (decedent) at the date of his death.

FINDINGS OF FACT

Some of the facts have been stipulated and are so found.

Decedent died testate on November...

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