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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect as of November 20, 1993, the
date of decedent's death, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
After settlement, the issue remaining for decision is the
value, as of the date of decedent's death, of 106,826 shares of
common stock of a closely held family corporation.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time of decedent's death, decedent resided in Tyler,
Texas, and at the time the petition was filed, the executor,
Harvey B. King, resided in Tyler, Texas.
Upon her death, decedent owned directly 60,743 shares or
2.71 percent, and indirectly through a family trust 158,967
shares or 7.08 percent, of the common stock of Brookshire Grocery
Co. (Brookshire). Decedent’s stock interest in Brookshire
represented a total of 219,710 shares or 9.79 percent of the
total 2,243,727 shares outstanding.
Brookshire was founded by Wood T. Brookshire in the 1920's
and was incorporated in Texas in 1953. Brookshire owned and
operated a chain of 96 retail grocery stores located primarily in
rural communities in Texas, Louisiana, and Arkansas.
Brookshire common stock is closely held by relatives of Wood
T. Brookshire, by current and former employees of Brookshire and
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