Estate of Duilio Costanza - Page 2

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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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