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ESTATE OF FOOTE v. COMMISSIONER

Docket No. 621-98.

77 T.C.M. 1356 (1999)

T.C. Memo. 1999-37

Estate of Dorothy B. Foote, Deceased, John Brumder and Carol Collins, Personal Representatives v. Commissioner.

United States Tax Court.

Filed February 5, 1999.

Attorney(s) appearing for the Case

James William Callison and Jeanne M. Coleman, for the petitioner. Frederick J. Lockhart, Jr. and John A. Weeda, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

Respondent determined a $52,340.53 deficiency in the Federal estate tax of the Estate of Dorothy B. Foote. Following concessions, the sole issue for decision is the fair market value (after application of the appropriate blockage discount) of 280,507 shares of Applied Power, Inc. (Applied Power or the company) class A common stock (Applied Power stock) held by Dorothy B. Foote's (decedent) revocable...

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