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manufacturer subsequently renamed Modern Globe, Inc., with
an estate tax value of $371,500; 49 percent of the common
stock of Pohatcong Hosiery Mills, Inc. (Pohatcong Hosiery),
a personal holding company with an estate tax value of
$812,918; 4 percent of the common shares of Vesta Corp.,
a personal holding company, with an estate tax value of
$15,756; and 25 percent of the common stock of Fairlee
Textile Co. (Fairlee), a personal holding company with
an estate tax value of $52,760. On audit, respondent
determined the Federal estate tax value of Mr. de
St. Aubin's gross estate to be $5,699,575.48 and the
value of the adjusted gross estate to be $3,848,912.65.
Respondent allowed an estate tax marital deduction of
$1,924,456.33.
On May 15, 1968, the town of Hempstead, New York,
condemned the Malibu Beach property. Mr. de St. Aubin's
estate engaged the town in protracted litigation regarding
the value of the property. The estate received interim
payments against the condemnation award in 1969 and 1972,
totaling $939,000. The estate used these interim payments
to pay at least a portion of its expenses. The town paid
the estate interest of $141,800 on the interim payments in
1973. In 1985, the parties reached a settlement in which
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