T.C. Memo. 2005-235
UNITED STATES TAX COURT
ESTATE OF WEBSTER E. KELLEY, DECEASED, JOHN R. LOUDEN AND
PATRICIA L. LOUDEN, PERSONAL REPRESENTATIVES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16894-03. Filed October 11, 2005.
Larry W. Gibbs, for petitioner.
Kathryn F. Patterson, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respondent determined a $136,679 deficiency
in the Federal estate tax of the Estate of Webster E. Kelley (the
estate). The sole issue for decision is the fair market value of
Webster E. Kelley’s (decedent) 94.83-percent interest in a family
limited partnership and one-third interest in a limited liability
company.
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