T.C. Memo. 2000-12                                   
                               UNITED STATES TAX COURT                                
                   ESTATE OF BEATRICE ELLEN JONES DUNN, DECEASED,                     
               JESSE L. DUNN, III, INDEPENDENT EXECUTOR, Petitioner v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 2312-95.                  Filed January 12, 2000.           
               David C. Allie and Walter B. Thurmond, for petitioner.                 
               Richard T. Cummings, for respondent.                                   
                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               GALE, Judge:  Respondent determined a deficiency in                    
          petitioner’s Federal estate tax of $238,515.05, which by                    
          subsequent amendment to the answer was increased to $1,100,000.             
          After concessions, the sole issue remaining for decision is the             
          fair market value of 492,610 shares of stock in Dunn Equipment,             
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