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contends; or some other amount. We hold that decedent owned
81,641 shares at the time of her death.
2. Whether, for purposes of computing the taxable estate
of decedent, the fair market value of the shares of Johnco common
stock included in decedent's gross estate was $4,100,000 ($50.94
per share) as petitioner contends, at least $6,278,899 ($77 per
share) as respondent contends, or some other amount. We hold
that the fair market value was $5,784,477 ($71 per share).
3. Whether the method prescribed for the computation of
the Federal estate tax transforms any part of such tax into a
direct tax which has not been apportioned in accordance with the
Constitution. We hold that it does not.
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect on the date of decedent’s death,
and all Rule references are to the Tax Court Rules of Practice
and Procedure. All amounts have been rounded to the nearest
whole dollar. Some of the facts have been stipulated and are
incorporated herein by this reference.
FINDINGS OF FACT
I. Decedent
Petitioner is the Estate of Helen Bolton Jameson, deceased
(the Estate), who died testate on September 22, 1991. Northern
Trust Bank of Texas (Northern Trust) is the independent executor
of the Estate. Decedent was a resident of Texas at the time of
her death. Decedent was predeceased by her husband, John B.
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