                                 T.C. Memo. 2004-39                                   


                               UNITED STATES TAX COURT                                


            ESTATE OF IDA ABRAHAM, DECEASED, DONNA M. CAWLEY AND DIANA A.             
                       SLATER, ADMINISTRATRIXES, Petitioner v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 7071-01.            Filed February 18, 2004.                

               Brendan J. Shea, for petitioner.                                       
               Carina J. Campobasso, for respondent.                                  


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        


               RUWE, Judge:  The Estate of Ida Abraham (the estate) seeks a           
          redetermination of respondent’s deficiency determination of an              
          estate tax of $1,125,210.  The sole question presented is whether           
          the full date of death value of three family limited partnerships           
          is includable in the taxable estate of Ida Abraham (decedent)

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