T.C. Memo. 2001-92
UNITED STATES TAX COURT
ESTATE OF MARY B. BULL, DECEASED, JOHN N. EDDY AND THOMAS R.
EDDY, CO-EXECUTORS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4908-99. Filed April 13, 2001.
Karen L. Hawkins, for petitioner.
G. Michelle Ferreira, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined an estate tax
deficiency in the amount of $347,219, all of which is in dispute.
The following three issues are in controversy: (1) Whether the
reported value of a partially completed personal residence should
be increased to reflect its value if completed because of the
possibility of insurance recovery or reimbursement; (2) whether,
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