- 31 -                                         
          Multiplied by decedent’s interest in                                        
               CSB                               71.43%                               
          Decedent’s pro rata share of CSB’s                                          
               earned but unpaid profits                       897,594                
                                                            907,594                   
          15-percent control premium                        136,139                   
          Respondent’s concession (see supra n.6)            62,029                   
          Value of decedent’s CSB stock                     1,105,762                 
          F.   Income in Respect of a Decedent                                        
               Section 691(a)(1)(A) provides, in pertinent part, as                   
          follows:                                                                    
                    SEC. 691(a).  Inclusion in Gross Income.                          
                    (1) General Rule.--The amount of all items of                     
               gross income in respect of a decedent which are not                    
               properly includible in respect of the taxable period                   
               in which falls the date of his death or a prior period                 
               * * * shall be included in the gross income, for the                   
               taxable year when received, of:                                        
                    (A) the estate of the decedent, if the right to                   
               receive the amount is acquired by the decedent's estate                
               from the decedent;                                                     
               Section 691 and its predecessor, section 126 of the Internal           
          Revenue Code of 1939, were enacted to accomplish the general                
          purpose of the Internal Revenue Code that a tax should be paid on           
          all income and “that death should not rob the United States of              
          the revenue which otherwise it would have had.”  Linde v.                   
          Commissioner, 213 F.2d 1, 5 (9th Cir. 1954), remanding 17 T.C.              
          584 (1951).                                                                 
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