Estate of James J. Renier, Deceased, Kent L. Renier and Dubuque Bank & Trust Company, Co-Executors - Page 2

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               1.  What was the fair market value of the 22,100 shares of             
          stock in the Renier Company held by James J. Renier (decedent) at           
          his death on April 10, 1994 (valuation date).                               
               2.  Whether the estate is liable for an addition to tax                
          under section 6662(a) for a substantial estate or gift tax                  
          valuation understatement.1                                                  
               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 and                  
          attached exhibits.  At the time of filing the petition, co-                 
          executor Kent L. Renier resided, and co-executor Dubuque Bank &             
          Trust Company had its principal place of business, in Dubuque,              
          Iowa.  Decedent resided in Dubuque, Iowa, on the date of his                
          death, and his will was probated in the Iowa District Court for             
          Dubuque County.                                                             

               1 The estate also alleged in the petition that respondent              
          erred in disallowing a deduction by the estate for charitable               
          bequests totaling $12,500.  However, the estate made no argument            
          at trial or on brief concerning that allegation, and we consider            
          it abandoned.  See Rybak v. Commissioner, 91 T.C. 524, 566 n.19             
          (1988); Bowman v. Commissioner, T.C. Memo. 1997-52 n.1, affd.               
          without published opinion 149 F.3d 1167 (4th Cir. 1998).                    

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