T.C. Memo. 1999-43
UNITED STATES TAX COURT
ESTATE OF HELEN BOLTON JAMESON, DECEASED,
NORTHERN TRUST BANK OF TEXAS N.A., INDEPENDENT EXECUTOR,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2322-96. Filed February 9, 1999.
S. Stacy Eastland, John W. Porter, and Margaret W. Brown,
for petitioner.
Melanie R. Urban and Lillian D. Brigman, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge: Respondent determined a deficiency in
petitioner's Federal estate tax of $4,241,832. After
concessions, the issues for decision are:
1. Whether, at the time of her death, Helen Bolton Jameson
(decedent) owned 80,485 shares of Johnco, Inc. (Johnco) common
stock, as petitioner contends; 81,251 shares, as respondent
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