Estate of William G. Adams, Jr. Deceased, George W. Saenger, Executor - Page 2




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          28, 1995, was $1,746,000, as respondent determined, or $920,800,            
          as the estate contends.  We hold that it was $1,161,705.                    
               Unless otherwise specified, section references are to the              
          Internal Revenue Code as amended and in effect on the date of               
          decedent’s death, and 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.               
          A.   Decedent and the Executor                                              
               Decedent, who lived in Asheville, North Carolina, died                 
          testate on September 28, 1995.  When he died, he owned 178 shares           
          of WSA voting common stock, which was 61.59 percent of its                  
          outstanding stock.  Voting common stock was WSA’s only                      
          outstanding stock when decedent died.                                       
               George W. Saenger, the executor of decedent’s estate, lived            
          in Asheville, North Carolina, when the petition was filed.                  
          B.   Waddell Sluder Adams & Co., Inc.                                       
               1.   Insurance Business                                                
               WSA has been an S corporation since the early 1970s.  It has           
          two components, a retail insurance agency and a managing general            
          insurance agency (MGA).  In 1995, the retail agency generated 5             
          percent of WSA’s revenue, and the MGA generated 95 percent.  The            
          retail agency sells insurance to the public.                                








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