T.C. Memo. 2004-39
UNITED STATES TAX COURT
ESTATE OF IDA ABRAHAM, DECEASED, DONNA M. CAWLEY AND DIANA A.
SLATER, ADMINISTRATRIXES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7071-01. Filed February 18, 2004.
Brendan J. Shea, for petitioner.
Carina J. Campobasso, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: The Estate of Ida Abraham (the estate) seeks a
redetermination of respondent’s deficiency determination of an
estate tax of $1,125,210. The sole question presented is whether
the full date of death value of three family limited partnerships
is includable in the taxable estate of Ida Abraham (decedent)
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