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CLARKE v. COMMISSIONER

Docket No. 6167-73.

35 T.C.M. 1482 (1976)

T.C. Memo. 1976-328

Estate of Victor P. Clarke, Deceased, Victor E. Clarke, Executor v. Commissioner.

United States Tax Court.

Filed October 28, 1976.

Attorney(s) appearing for the Case

Kenneth G. Anderson, Suite 655, Florida National Bank Bldg., Jacksonville, Fla., and George H. DeCarion, Suite 1211, 100 Biscayne Blvd., Miami, Fla., for the petitioner. Steedly Young, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

Respondent determined a deficiency in the federal estate tax due from the Estate of Victor P. Clarke in the amount of $904,700.78.1 In his Amendment to Answer respondent asserts that the deficiency in estate tax due is $1,046,229.95. Due to concessions by the parties the issues for our consideration are:

(1) the value on the date of his death of 550 shares of the...

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