Estate of Ruth J. Casey, Deceased, First Interstate Bank of Nevada, Special Administrator - Page 1

                                 T.C. Memo. 1996-156                                  

                               UNITED STATES TAX COURT                                

                 ESTATE OF RUTH J. CASEY, DECEASED, FIRST INTERSTATE                  
                BANK OF NEVADA, SPECIAL ADMINISTRATOR, Petitioner v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 19512-94.             Filed March 27, 1996.                 

               Casey W. Vlautin, for petitioner.                                      
               Paul L. Dixon, for respondent.                                         

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               GERBER, Judge:  Respondent determined a $716,355 deficiency            
          in petitioner’s Federal estate tax.  The parties have agreed to             
          the fair market value of certain property included in the estate            
          before the application of any discount, but they disagree about             
          the amount of any such discount.                                            

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