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ESTATE OF BORGATELLO v. COMMISSIONER

Docket No. 24756-97.

80 T.C.M. 260 (2000)

T.C. Memo. 2000-264

Estate of Charles A. Borgatello, Deceased, C. Norman Borgatello and Josephine E. Donnelly, Co-Executors, and C. Norman Borgatello, Successor Trustee to The Charles A. Borgatello Living Trust v. Commissioner.

United States Tax Court.

Filed August 18, 2000.

Attorney(s) appearing for the Case

John W. Ambrecht and Gregory Arnold, for the petitioners. Donna F. Herbert, for the respondent.

MEMORANDUM OPINION

WELLS, Chief Judge:

Respondent determined a deficiency of $3,424,504 in the Federal estate tax of the estate of Charles A. Borgatello (the estate). After concessions, the issues we must decide involve the fair market value of stock representing an 82.76-percent interest in Valley Improvement Co., Inc. (VIC)1 as of January 12, 1994. To value the 82.76-percent shareholder's

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