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The issues for decision are: (1) Whether the fair market
value of 12,889 shares of Savings Bank of Mendocino County
(Savings) on the date of decedent's death was $300 per share as
respondent determined in the notice of deficiency; $181.50, as
petitioner reported on its estate tax return; or some other
amount. We hold it was $276 per share. (2) Whether the fair
market value of 500 shares of common stock of Bank of Willits
(Willits) on the date of decedent's death was $850 per share, as
respondent determined in the notice of deficiency; $485 per
share, as petitioner reported on its estate tax return; or some
other amount. We hold it was $626 per share. (3) Whether, under
section 2053,1 petitioner may deduct certain expenses incurred in
defending its reporting position. We hold it may.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, supplemental stipulation of facts, and
second supplemental stipulation of facts, and the accompanying
exhibits are incorporated herein by this reference.
Petitioner is the estate of Frank A. Branson (decedent), who
died testate on November 9, 1991, in Mendocino, California. Mary
1All section references are to the Internal Revenue Code in
effect as of the date of decedent's death, and all Rule
references are to the Tax Court Rules of Practice and Procedure,
unless otherwise indicated. All dollar amounts are rounded to
the nearest dollar, unless otherwise indicated.
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