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ESTATE OF STONE, III v. COMMISSIONER

Docket No. 13647-01, 14195-01.

86 T.C.M. 551 (2003)

T.C. Memo. 2003-309

Estate of Eugene E. Stone, III, Deceased, C. Rivers Stone, E.E. Stone, IV, Mary Stone Fraser & Rosalie Stone Morris, Co-Personal Representatives v. Commissioner. Estate of Allene W. Stone, Deceased, C. Rivers Stone, Independent Executor v. Commissioner.

United States Tax Court.

Filed November 7, 2003.

Attorney(s) appearing for the Case

John W. Porter, Stephanie Loomis-Price, and Robert E. August, for the petitioners.

J. Craig Young, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge:

Respondent determined deficiencies in Federal estate tax (estate tax) with respect to the Estate of Eugene Earle Stone, III (Mr. Stone's estate), and the Estate of Allene W. Stone (Ms. Stone's estate) in the amounts of $3,268,401 and $741,809, respectively. The only issue remaining for decision in the case of Mr. Stone's estate is whether certain assets owned by each of five family limited partnerships...

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