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ESTATE OF DESMOND v. COMMISSIONER

Docket No. 26237-96.

77 T.C.M. 1529 (1999)

T.C. Memo. 1999-76

Estate of William J. Desmond, Deceased, Donn Kemble, Executor v. Commissioner.

United States Tax Court.

Filed March 10, 1999.

Attorney(s) appearing for the Case

Donn Kemble, Irvine, Calif., for the petitioner. Jeffrey A. Schlei and Michael H. Salama, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

Respondent determined a deficiency of $1,055,053 in, and a section 6662(b)(1) penalty of $211,011 on, the Federal estate tax of the estate of decedent William J. Desmond.1

After concessions,2 the sole issue for decision is the fair market value of: (1) Decedent's interest in Deft, Inc. (Deft), and (2) real property located at 12 Rue Verte...

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