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ESTATE OF BAILEY v. COMMISSIONER

Docket No. 15005-99.

83 T.C.M. 1862 (2002)

T.C. Memo. 2002-152

Estate of Lewis A. Bailey, Deceased, Frances Jeanette Foster, Executrix v. Commissioner.

United States Tax Court.

Filed June 17, 2002.

Attorney(s) appearing for the Case

James Allen Brown, for the petitioner.

William F. Castor, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

THORNTON, Judge:

Respondent determined a $119,731 Federal estate tax deficiency with respect to the estate of Lewis A. Bailey (the estate). After concessions, the issues for decision are: (1) The date-of-death value of decedent's 25-percent interest in C&L Bailey, Inc. (C&L Bailey); (2) the date-of-death value of a 25-percent interest in C&L Bailey that was held in a qualified terminable interest property...

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