Estate of Harriet R. Mellinger, Deceased, Hugh V. Hunter and Wells Fargo Bank, Co-Executors - Page 2




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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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