T.C. Memo. 1996-414
UNITED STATES TAX COURT
ESTATE OF ARTHUR G. SCANLAN, DECEASED, RUTH B. SCANLAN,
ADMINISTRATRIX, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 4561-95. Filed September 16, 1996.
P moves for reconsideration, arguing that the
Court erred because we: (1) Concluded that the subject
shares were marketable, (2) failed to account properly
for minority and marketability discounts, and (3) did
not apply the standards set forth in Mandelbaum v.
Commissioner, T.C. Memo. 1995-255, affd. without
published opinion 91 F.3d 124 (3d Cir. 1996), to
determine the marketability discount. Held: P's
motion for reconsideration will be denied.
Robert R. Casey, for petitioner.
Linda K. West, for respondent.
* Estate of Scanlan v. Commissioner, T.C. Memo. 1996-331.
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