Estate of Helen Bolton Jameson, Deceased, Northern Trust Bank of Texas N.A., Independent Executor - Page 2

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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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