T.C. Memo. 2002-152
UNITED STATES TAX COURT
ESTATE OF LEWIS A. BAILEY, DECEASED, FRANCES JEANETTE FOSTER,
EXECUTRIX, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15005-99. Filed June 17, 2002.
James Allen Brown, for petitioner.
William F. Castor, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge: Respondent determined a $119,731 Federal
estate tax deficiency with respect to the estate of Lewis A.
Bailey (the estate). After concessions, the issues for decision
are: (1) The date-of-death value of decedent’s 25-percent
interest in C&L Bailey, Inc. (C&L Bailey); (2) the date-of-death
value of a 25-percent interest in C&L Bailey that was held in a
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