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value of certain real estate conveyed by his trust in exchange
for a self-canceling installment note (SCIN). Unless otherwise
indicated, section references are to the Internal Revenue Code
applicable to the date of decedent's death. Rule references are
to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some facts have been stipulated and are so found. The
stipulation of facts and the exhibits submitted therewith are
incorporated herein by this reference. Decedent died on May 12,
1993, and the executor of his estate was his son, Michael.
Decedent resided in Burton, Michigan, at the time of his death,
and Michael resided in Grand Blanc, Michigan, when the petition
was filed.
Decedent was born in Italy on October 21, 1919. He came to
the United States and worked as a welder for General Motors,
Incorporated (GM) until 1966. Following his retirement from GM,
he and his wife, Mary Ann, opened an Italian restaurant called
Latina Restaurant and Pizzeria, Inc., (Latina restaurant) on
property they owned in Flint, Michigan, at 1370 Bristol Road
West. The property was an irregularly shaped parcel of land on
1.91 net acres with 65 feet of frontage on Bristol Road and one
curb cut.
During the early 1980's, decedent and his wife built a small
retail/office plaza, called "Bristol West", on property they
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