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ESTATE OF JAMESON v. COMMISSIONER

Docket No. 2322-96.

77 T.C.M. 1383 (1999)

T.C. Memo. 1999-43

Estate of Helen Bolton Jameson, Deceased, Northern Trust Bank of Texas N. A., Independent Executor v. Commissioner.

United States Tax Court.

Filed February 9, 1999.

Attorney(s) appearing for the Case

S. Stacy Eastland, Houston, Tex., John W. Porter, and Margaret W. Brown, for the petitioner. Melanie R. Urban and Lillian D. Brigman, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GALE, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax of $4,241,832. After concessions, the issues for decision are:

1. Whether, at the time of her death, Helen Bolton Jameson (decedent) owned 80,485 shares of Johnco, Inc. (Johnco) common stock, as petitioner contends; 81,251 shares, as respondent contends; or some other amount. We hold that decedent owned 81,641 shares at the time...

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