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ESTATE OF NAIL v. COMMISSIONER

Docket No. 1459-70.

59 T.C. 187 (1972)

ESTATE OF CHLOE A. NAIL, DECEASED, J. H. NAIL, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 26, 1972.

Attorney(s) appearing for the Case

Whitfield J. Collins, Jack C. Wessler, and Harry E. Bartel, for the petitioner.

John W. Dierker, for the respondent.

SIMPSON, Judge:

The respondent determined a deficiency of $449,301.65 in the Federal estate tax of the Estate of Chloe A. Nail. Most of the issues have been settled, and the only issue to be decided concerns the valuation of the surface estate in 20,480 acres of land in Shackelford County, Tex.

FINDINGS OF FACT

Some of the facts have been stipulated, and those facts are so found.

The petitioner, J. H. Nail, is the independent executor...

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