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ESTATE OF DOUGHERTY v. COMMISSIONER

Docket No. 35129-83.

59 T.C.M. 772 (1990)

T.C. Memo. 1990-274

Estate of Albert L. Dougherty, Deceased, Allen L. Dougherty and Charlotte K. Dougherty, Co-executors v. Commissioner.

United States Tax Court.

Filed May 31, 1990.

Attorney(s) appearing for the Case

Robert E. Johnson, Marc A. Hetzner, Roger L. Kessler, and Lisa A. Lutz, for the petitioner. Elsie Hall, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined a deficiency of $1,882,702.95 in the Federal estate tax liability of the estate of Albert L. Dougherty. After concessions1, the issues to be decided are 1) the fair market value of the decedent's 1,504-acre tract of real property located in Charlotte County, Florida; and 2) the fair market value of the decedent's 100-percent beneficial interest in the...

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