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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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