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September 2, 1996, fair market value of the 11.6-percent interest
in Glenwood State Bank (Glenwood Bank) that Helen N. Noble
(decedent) owned. The estate’s Form 706, United States Estate
(and Generation-Skipping Transfer) Tax Return (estate tax
return), reported the fair market value as $903,988. Respondent
determined in the notice of deficiency that the fair market value
was $1.1 million. Petitioners currently argue that the fair
market value was $841,000 or less. Respondent argues that the
fair market value was $1.1 million, as determined.
We hold that the fair market value of the interest was
$1,067,000. Unless otherwise noted, section references are to
the applicable versions of the Internal Revenue Code, and Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
The parties filed with the Court a stipulation of 14 facts
and 2 accompanying exhibits; namely, the estate tax return and
the notice of deficiency. We have found the stipulated facts
accordingly and have found other facts from the two exhibits.
Decedent died on September 2, 1996, while residing in Gage
County, Nebraska. John R. Noble and Leslie H. Noble, Jr., the
co-personal representatives of the estate, resided in Lincoln,
Nebraska, when the petition was filed in this Court.
The estate filed the estate tax return on July 23, 1998.
Estate tax return reported that decedent’s gross estate included
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