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ESTATE OF KESSLER v. COMMISSIONER

Docket No. 1387-76.

37 T.C.M. 1851 (1978)

T.C. Memo. 1978-491

Estate of Bernard Kessler, Deceased, Mitchell W. Rabbino, Executor v. Commissioner.

United States Tax Court.

Filed December 11, 1978.

Attorney(s) appearing for the Case

Richard J. Carter, Jr. and Arthur J. Mahon, 20 Broad St., New York, N.Y., for the petitioner. Gerald J. O'Toole and Alyce C. Halchak, for the respondent.

Memorandum Findings of Fact and Opinion

QUEALY, Judge:

Respondent determined a deficiency in the estate tax of Bernard Kessler, the decedent, in the amount of $465,492.10. The estate claims an overpayment of tax. Respondent has amended his pleadings to claim an increased deficiency.

The sole question for decision is the fair market value as of October 21, 1972, of 326,720 shares of common stock of Unishops, Inc., a merchandising chain.

Findings...

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