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ESTATE OF GLOECKNER v. C.I.R.

Docket No. 97-4007.

152 F.3d 208 (1998)

ESTATE OF Frederick Carl GLOECKNER, Deceased, Joseph A. Simone, Executor and Douglas Dillon, Executor, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided August 18, 1998.

Attorney(s) appearing for the Case

James E. Daniels, New York, New York (Landis Olesker, Steven D. Goldberg, Hara K. Jacobs, Hall Dickler Kent Friedman & Wood LLP, New York, New York, of counsel), for Petitioners-Appellants.

Curtis C. Pett, Washington, D.C. (Teresa E. McLaughlin, Tax Division, Loretta C. Argrett, Assistant Attorney General, Department of Justice, Washington, D.C., of counsel), for Respondent-Appellee.

Before: OAKES, CARDAMONE, and CALABRESI, Circuit Judges.

CARDAMONE, Circuit Judge:

This appeal is brought by petitioners, who are the executors of the estate of Frederick Carl Gloeckner. The Commissioner of Internal Revenue, in reviewing the estate tax return for decedent Gloeckner, assigned a greater value than that which was claimed for shares of stock Gloeckner owned in a closely-held corporation he had founded. Petitioners reported the value of these shares to be the value set forth in a redemption agreement between...

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