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SUPPLEMENTAL MEMORANDUM OPINION
LARO, Judge: Estate of Arthur G. Scanlan, Deceased,
Ruth B. Scanlan, Administratrix, moves the Court to reconsider
our memorandum opinion, T.C. Memo. 1996-331. See Rule 161.1
In our memorandum opinion, the facts and holding of which are
incorporated herein by this reference, we found and held that the
per share value of the decedent’s stock was $50.50885 on the date
of his death and the date of a prior gift. Petitioner had argued
that the per share values were $35.20 at death and $34.84 on the
date of the gift. Respondent had determined that the per share
values were $72.15 on both dates.
Petitioner alleges in its motion (and accompanying
memorandum of law) 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
1 Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011