HESS v. COMMISSIONER

Docket No. 10468-01.

86 T.C.M. 303 (2003)

T.C. Memo. 2003-251

Johann T. and Johanna Hess v. Commissioner.

United States Tax Court.

Filed August 20, 2003.


Attorney(s) appearing for the Case

Timothy C. Frautschi and Maureen A. McGinnity, for the petitioners.

George W. Bezold and Mark J. Miller, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge.

Respondent determined a deficiency of $261,950 in petitioner Johann Hess's Federal gift tax for taxable year 1995. Respondent also determined a deficiency of $261,950 in petitioner Johanna Hess's Federal gift tax for taxable year 1995. The issue for decision is the fair market value under section 25011 of 10 shares of stock...

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