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ESTATE OF DAVIS v. COMMISSIONER

Docket No. 28647-90.

65 T.C.M. 2365 (1993)

T.C. Memo. 1993-155

Estate of Ethlyn Davis, Deceased, Don M. Davis, Executor v. Commissioner.

United States Tax Court.

Filed April 8, 1993.

Attorney(s) appearing for the Case

Francis M. Smith and Michael M. Billion, 310 S. First Ave, Sioux Falls, S.D., for the petitioner. J. Anthony Hoefer, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge.

Respondent, by means of a statutory notice of deficiency, determined a $678,103 Federal estate tax deficiency. The primary issue concerns the value, for estate tax purposes, of the cause of action against Merrill Lynch, Pierce, Fenner & Smith, Inc. (Merrill Lynch). The litigation involved claims for compensatory and punitive damages in a security churning1 case. We also...

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