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(decedent) held one-third of the stock of JFI and 12 percent of
the stock of FNBW.
Unless otherwise noted, 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 are so found. We
incorporate by this reference the stipulation of facts, the
supplemental stipulation of facts, and the attached exhibits. At
the time of filing the petition, coexecutor Frederic L. Foill II
resided in Waverly, Ohio, and the estate of decedent was
administered in Pike County, Ohio. The parties have stipulated
that the estate had a Waverly, Ohio, address at the time the
petition was filed.
JFI
JFI was an Ohio corporation that operated a farm in Pike
County, Ohio, that had been in decedent’s family for many years.
JFI was an S corporation within the meaning of section 1361(a).
Pike County is a rural, primarily agricultural county with low
economic growth. In 1942, decedent and her two sisters each
inherited a one-third interest in their father’s farm. When the
farm was later incorporated as JFI, each sister received
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