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ESTATE OF WELLS v. COMMISSIONER

Docket No. 5691-66.

50 T.C. 871 (1968)

ESTATE OF FRANCES FOSTER WELLS, DECEASED, EUGENE P. RUEHLMANN, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 16, 1968.

Attorney(s) appearing for the Case

Michael D. Rose, for the petitioner.

Conley G. Wilkerson, for the respondent.

OPINION

TIETJENS, Judge:

The Commissioner determined a deficiency in estate tax in the amount of $2,328.25.

The only issue is whether the Commissioner properly valued for estate tax purposes the shares of certain open-end investment companies. He valued them pursuant to section 20.2031-8(b),1 Estate Tax Regs., the validity of which is in contention.

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