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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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