Estate of Frederick Carl Gloeckner, Deceased, Joseph A. Simone, and Douglas Dillon, Co-Executors - Page 2

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               James E. Daniels and Steven D. Goldberg, for petitioner.               
               Drita Tonuzi and Cheryl A. McInroy, for respondent.                    


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               HALPERN, Judge:  Respondent determined a deficiency in                 
          Federal estate tax liability of $2,951,937.  The sole issue                 
          remaining for decision is the value of certain shares of stock              
          that Frederick Carl Gloeckner (decedent) owned on the date of his           
          death.  All section references are to the Internal Revenue Code             
          in effect at the time of decedent’s death, and all Rule                     
          references are to the Tax Court Rules of Practice and Procedure.            
                                  FINDINGS OF FACT                                    
               Some facts have been stipulated and are so found.  The                 
          stipulation of facts filed by the parties and accompanying                  
          exhibits is incorporated herein by this reference.                          
          Decedent                                                                    
               Decedent died testate on July 28, 1990.  The co-executors of           
          decedent’s estate (the estate) are Joseph A. Simone and Douglas             
          Dillon (collectively, the executors).  Decedent was survived by a           
          nephew, a niece, a grandnephew, and a grandniece (his kin).                 
          Fred C. Gloeckner & Company                                                 
               Fred C. Gloeckner & Co., Inc. (the company), is a New York             
          corporation organized in 1934.  At least until the time of                  
          decedent’s death, the principal place of business of the company            





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