T.C. Memo. 2001-229
UNITED STATES TAX COURT
ESTATE OF PATTIE WELDER EDWARDS, DECEASED, OAKES DAVID EDWARDS,
JR., AND PATRICIA EDWARDS CARSON, CO-EXECUTORS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10172-99. Filed August 23, 2001.
Terrell W. Dahlman and Frederick F. Rogers, Jr., for
petitioner.
Gerald L. Brantley, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined a deficiency of
$523,771 in the 1994 Federal estate tax of the estate of Pattie
Welder Edwards (the estate). After concessions, the issue for
decision is whether the ranch properties owned by decedent at her
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