T.C. Memo. 1998-167
UNITED STATES TAX COURT
ESTATE OF PAULINE WELCH, DECEASED, NEWTON G. WELCH, JR. AND LOIS
WELCH MCGOWAN, CO-EXECUTORS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27513-96. Filed May 6, 1998.
James David Leckrone, for petitioner.
William W. Kiessling, for respondent.
MEMORANDUM OPINION
LARO, Judge: The Estate of Pauline Welch (the estate)
petitioned the Court to redetermine respondent's determination of
a deficiency in the amount of $59,987 in its Federal estate tax.
Following concessions by both parties, the remaining issue is
whether the estate is entitled to discount the value of stock for
built-in capital gains tax liability. Unless otherwise stated,
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