T.C. Memo. 1997-241
UNITED STATES TAX COURT
ESTATE OF JUANITA F. SIRMANS, DECEASED,
DAN L. SIRMANS, EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8466-94. Filed May 28, 1997.
David M. Green and Thomas Gallo, for petitioner.
Lawrence B. Austin and Lawrence Green, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WHALEN, Judge: Respondent determined an estate tax
deficiency of $123,087.43 with respect to the Estate of
Juanita F. Sirmans, Deceased. After concessions, the sole
issue for decision is the date-of-death value of certain
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