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ESTATE OF CHARANIA v. COMMISSIONER OF INTERNAL REVENUE

No. 16367-07.

133 T.C. No. 7

ESTATE OF NOORDIN M. CHARANIA, DECEASED, FARHANA CHARANIA, MEHRAN CHARANIA AND ROSHANKHANU DHANANI, ADMINISTRATORS, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 14, 2009.

Attorney(s) appearing for the Case

Diane Currier Ryan, William F. Sheehan, and Laura Rees Acosta, for petitioners.

Mary P. Hamilton, for respondent.

OPINION

COHEN, Judge:

Respondent determined a deficiency in the Federal estate tax of the Estate of Noordin M. Charania (the estate) in the amount of $2,070,000.01 and an addition to tax under section 6651(a)(1) for the late filing of the estate tax return. The issues for decision are: (1) Whether the value of the gross estate includes the value of all of the shares of a U.S. corporation registered in the name of Noordin M. Charania (decedent), a nonresident...

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