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or the company) class A common stock (Applied Power stock) held by
Dorothy B. Foote's (decedent) revocable trust (the Trust) as of
November 27, 1993, the date of decedent's death.
All section references are to the Internal Revenue Code as
amended and in effect at decedent's date of death, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulations
of facts are incorporated in our findings by this reference.
On the date of her death, November 27, 1993, decedent was a
resident of Martin County, Florida. John Brumder and Carol Collins
were duly appointed co-personal representatives of decedent's
estate. Mr. Brumder resided in Boulder, Colorado, and Ms. Collins
resided in Longmont, Colorado, at the time the petition in this
case was filed.
The Applied Power Stock
Applied Power, incorporated in 1910, is an international
manufacturing and distribution company that supplies equipment for
various motion and position control applications to a variety of
industries, including construction, transportation, natural
resource, aerospace, and defense. Its stock is traded on the New
York Stock Exchange (NYSE).
Applied Power's operations are divided into two groups:
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