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ESTATE OF HELEN A. v. COMMISSIONER

Docket Nos. 9308-01, 9309-01.

85 T.C.M. 1497 (2003)

T.C. Memo. 2003-176

Estate of Helen A. Deputy, Deceased, William J. Deputy, Co-Executor v. Commissioner.

United States Tax Court.

Filed June 13, 2003.

Attorney(s) appearing for the Case

Albert L. Grasso, Donald J. Russ, Jr., and John P. Adams, for the petitioner.

Michael F. O'Donnell, Gregory J. Stull, and Thomas D. Yang, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

In these consolidated cases,1 respondent determined a $1,295,274 deficiency in estate tax and a $162,715 deficiency in gift tax. The parties have resolved all issues except for the fair market value of an interest in a closely held corporation that was included in decedent's estate as part of a family limited partnership.2

FINDINGS OF...

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