T.C. Memo. 1997-484
UNITED STATES TAX COURT
ESTATE OF THOMAS A. FLEMING, DECEASED, CATHY J. HIRT, INDEPENDENT
SUCCESSOR EXECUTRIX, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22462-95. Filed October 27, 1997.
William R. Cousins III, James R. Dobbs, Jr., Robert D.
Collier, and Robert M. Bolton, for petitioner.
John R. Hunter, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined a deficiency of
$512,881 in petitioner's Federal estate tax. The sole issue
remaining for decision is the fair market value of the stock
interest in a closely held corporation that was owned by Thomas
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