Estate of William Busch, Deceased, Mary Dana, Executor - Page 1

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                                  T.C. Memo. 2000-3                                   


                               UNITED STATES TAX COURT                                


                         ESTATE OF WILLIAM BUSCH, DECEASED,                           
                         MARY DANA, EXECUTOR, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 16441-97.          Filed January 5, 2000.                   

               Nickolas P. Tooliatos II and Erin Kvistad (specially                   
          recognized), for petitioner.                                                
               Elizabeth L. Groenewegen and Rebecca T. Hill, for                      
          respondent.                                                                 


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               GERBER, Judge:  Respondent determined that there should be             
          an increase in the reported value of certain real property                  
          resulting in a $1,974,500 Federal estate tax deficiency.                    
          Petitioner disagrees with respondent’s value determination and