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ESTATE OF SULLIVAN v. COMMISSIONER

Docket No. 19082-80.

45 T.C.M. 1199 (1983)

T.C. Memo. 1983-185

Estate of Elizabeth O'Herron Sullivan, Deceased, First-Citizens Bank & Trust Company and John Thomas Sullivan, Executors v. Commissioner.

United States Tax Court.

Filed April 5, 1983.

Attorney(s) appearing for the Case

B. Irvin Boyle, 623 Law Bldg., Charlotte, N.C., for the petitioners. Mathew E. Bates, for the respondent.

Memorandum Opinion

WHITAKER, Judge:

Respondent determined a deficiency of $2,261,356.75 in the Federal estate tax of the Estate of Elizabeth O'Herron Sullivan. The sole issue for decision is the fair market value of certain stock included in the estate.

All the facts have been stipulated and are found accordingly.

Elizabeth O'Herron Sullivan (hereinafter decedent) died on December 12, 1976. Petitioners are the executors of her estate. It...

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