T.C. Memo. 1999-129
UNITED STATES TAX COURT
ESTATE OF LYNN M. RODGERS, DECEASED, FIRST NATIONAL BANK OF
COMMERCE, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL
REVENUE, Respondent
Docket No. 761-92. Filed April 20, 1999.
Edward D. Wegmann and David F. Edwards, for petitioner.
Linda K. West, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined a deficiency of
$3,754,683.92 in petitioner's Federal estate tax (estate tax).
The sole issue remaining for decision is the fair market value of
the interest that Lynn M. Rodgers (decedent) owned on the date of
his death in Marrero Land and Improvement Association, Limited
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