Estate of Beatrice Ellen Jones Dunn - Page 2




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          Inc. (Dunn Equipment), owned by Beatrice Ellen Jones Dunn                   
          (decedent) on the date of her death, the valuation date.  Unless            
          otherwise noted, all section references are to the Internal                 
          Revenue Code in effect at the time 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.               
               Decedent died on June 8, 1991, at the age of 81.  Jesse L.             
          Dunn III (Mr. Dunn), decedent’s son, is the executor of the                 
          Estate of Beatrice Ellen Jones Dunn (estate).  At the time of               
          filing of the petition in this case, the estate was administered            
          in Texas City, Texas, and Mr. Dunn resided in Dickinson, Texas.             
               At the time of her death, decedent owned 492,610 shares of             
          stock in Dunn Equipment representing 62.96 percent of the total             
          outstanding shares.  At decedent’s death, Dunn Equipment was a              
          family-owned and family-operated company.  Dunn Equipment used a            
          fiscal year ending March 31 for tax and financial reporting                 
          purposes.  Dunn Equipment was incorporated in Texas in 1949.  As            
          of the valuation date, Dunn Equipment operated from four                    
          locations in Texas and had approximately 134 employees, three of            
          whom were executives and eight of whom were salesmen.  The                  






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