Estate of William F. Luton, Deceased, Nancy L. Jackson, Robert S. Herdman, and William F. Luton, Jr., Co-Executors - Page 9

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          parties for purposes of valuing the assets of the estate.                   
          Furthermore, we note that the general contract principle of                 
          contra proferentem weighs against respondent in this case.  The             
          principle states that an ambiguous provision in a written                   
          document is construed more strongly against the person who                  
          selected the language.  Rink v. Commissioner, 100 T.C. 319, 328             
          (1993) n.8; see e.g., United States v. Seckinger, 397 U.S. 203,             
          216 (1970).                                                                 
               Accordingly, we conclude that paragraphs 2 and 4 of the SPA            
          should be interpreted consistently with one another.  Therefore,            
          we hold that the Rule 155 computation shall be computed so that             
          the receivable amounts relating to the advances to Dune Lakes by            
          the decedent are not includable in the estate.                              
               To reflect the foregoing,                                              
                                             Decision will be entered in              
                                        accordance with the parties’                  
                                        Rule 155 computation as revised to            
                                        conform with this opinion.                    
















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