Estate of Emily F. Klauss - Page 2

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          was $1,810,000, as petitioner contends; $2,713,000, as respondent             
          contends; or some other amount.  We hold that it was $2,150,000.              
               Section references are to the Internal Revenue Code as in                
          effect when decedent died.  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.                 
          A.   Decedent                                                                 
               Decedent died on February 1, 1993 (the valuation date), in               
          San Antonio, Texas.  Her husband, William J. Klauss, predeceased              
          her.  Decedent’s son, John G. Klauss (John Klauss), is the                    
          independent executor of decedent’s estate.  He lived in Helotes,              
          Texas, when he filed the petition in this case.                               
          B.   Green Light Chemical Co., Inc.                                           
               1.   Formation                                                           
               William J. Klauss cofounded the Klauss-White Co. in 1946.                
          It changed its name to the Green Light Co., Inc. (Green Light),               
          in 1960.  He ran the company until the mid-1970's, and he died in             
               John Klauss worked for Green Light for 38 years.  He began               
          running the company in the mid-1970's, and he was the chairman of             
          the board on February 1, 1993.  He retired in 1994.                           

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