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ESTATE OF MITCHELL v. COMMISSIONER

Docket No. 21805-93.

74 T.C.M. 872 (1997)

T.C. Memo. 1997-461

Estate of Paul Mitchell, Deceased, Patrick T. Fujieki, Executor v. Commissioner.

United States Tax Court.

Filed October 9, 1997.

Attorney(s) appearing for the Case

David W.K. Wong, Honolulu, Hawaii, B. John Williams, Jr., Miriam Louise Fisher, Karen L. Hirsh, and Melvin E. Lefkowitz, for the petitioner. Henry E. O'Neill, Alan Summers, and Paul G. Robeck, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

Respondent determined a $45,117,089 Federal estate tax deficiency, an $8,396,020 penalty under section 6662(g), and a $147,623 penalty under section 6662(h). After concessions, the issues remaining for decision are: (1) The moment-of-death value of 1,226 shares of John Paul Mitchell Systems common stock; and (2) whether petitioner is liable for the section 6662(g) penalty.1

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