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COHEN, Chief Judge: Respondent determined a deficiency of
$10,574,983 in the Federal estate tax of the estate of
Harriett R. Mellinger (decedent). After concessions by the
parties, the issues remaining for decision are:
(1) Whether section 2044 requires aggregation, for valuation
purposes, of the stock held in a trust established by decedent's
predeceased spouse under section 2056(b)(7) with stock held in
decedent's revocable trust and with stock held outright by
decedent; and
(2) if section 2044 does not require aggregation, the fair
market value of the stock at decedent's death.
Unless otherwise indicated, all 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.
FINDINGS OF FACT
Some of the facts have been stipulated, and the facts set
forth in the stipulation are incorporated in our findings by this
reference. Decedent died testate on April 18, 1993 (the
valuation date), a resident of Los Angeles, California. Decedent
was the widow of Frederick N. Mellinger (Mr. Mellinger), founder
of Frederick's of Hollywood, Inc. (FOH).
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