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ESTATE OF FOLKS v. COMMISSIONER

Docket No. 2023-75.

43 T.C.M. 427 (1982)

T.C. Memo. 1982-43

Estate of T. John Folks, Jr., Deceased, Charles R. Carroll and Bernice M. Folks, Co-Executors v. Commissioner.

United States Tax Court.

Filed January 29, 1982.

Attorney(s) appearing for the Case

Donald A. Goldsmith, Thomas J. Lennon, and T. Randolph Harris, 1345 Avenue of the Americas, New York, N.Y., for the petitioner. Michael N. Balsamo, Victoria Wilson, and Michael A. DeLuca for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Respondent has determined a deficiency of $272,595.93 in the Federal estate tax of petitioner, subject to an additional credit for state death taxes allowable. The issues for decision are: (1) the proper valuation of decedent's shares of stock in two closely held corporations; (2) whether certain shares of stock held by the decedent as a custodian under the New York Uniform Gifts to Minors Act for...

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