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ESTATE OF DURKIN v. COMMISSIONER

Docket No. 47036-86.

63 T.C.M. 3111 (1992)

T.C. Memo. 1992-325

Estate of James Durkin, Sr., Deceased, James J. Durkin, Jr., Personal Representative, and Anna Jean Durkin v. Commissioner.

United States Tax Court.

Filed June 8, 1992.

Attorney(s) appearing for the Case

Thomas W. Ostrander, Mark E. Cedrone, and Joshua Sarner, One Liberty Place, Philadelphia, Pa., for the petitioners. Linda S. Bednarz and Ruth Spadaro, for the respondent.

Memorandum Findings of Fact and Opinion

COLVIN, Judge.

Respondent determined deficiencies of $75,293 for 1973, $244,229 for 1974, $4,234,380 for 1975, $124,345 for 1976, $72,325 for 1977, and $95,160 for 1978.

Following concessions and a conditional settlement of various issues, the issues for decision are:

(1) What was the fair market value of culm banks acquired by petitioners on June 26, 1975? We hold it was $7.25 million.

(2)...

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