Estate of Josephine T. Thompson, Deceased, Carl T. Holst-Knudsen and the Bank of New York, Executors - Page 2

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          Josephine T. Thompson and a $7,164,163 accuracy-related penalty             
          under section 6662(a).                                                      
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect on May 2, 1998, the date of             
          decedent’s death, and all Rule references are to the Tax Court              
          Rules of Practice and Procedure.                                            
               The issues for decision are:  (1) The fair market value of             
          487,440 shares of the voting common stock of Thomas Publishing              
          Co., Inc. (TPC), that were owned by decedent on her death; and              
          (2) whether the estate is liable for the accuracy-related                   
          penalty.                                                                    

                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               On May 2, 1998, the date of her death, decedent resided in             
          New York.                                                                   
               On May 14, 1998, Carl T. Holst-Knudsen (Holst-Knudsen),                
          decedent’s son, and The Bank of New York were appointed by the              
          Surrogate Court of the State of New York, County of Westchester,            
          as co-executors of decedent’s estate.  Holst-Knudsen resides in             
          New Jersey, and The Bank of New York is headquartered in New York           
          City.                                                                       
               TPC is a private, closely held corporation that was formed             
          over 100 years ago, on January 28, 1898, as a New York                      







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