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ESTATE OF JUNG v. COMMISSIONER

Docket No. 20221-88.

101 T.C. 412 (1993)

ESTATE OF MILDRED HERSCHEDE JUNG, DECEASED, RUTH J. CONWAY, EXECUTRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 10, 1993.

Attorney(s) appearing for the Case

Michael E. Neiheisel, James M. Moore, Paul D. Ratterman, and Thomas H. Clark, for petitioner.

Joseph P. Grant, for respondent.

CHABOT, Judge:

Respondent determined a deficiency in Federal estate tax against petitioner in the amount of $2,396,902.92. By amendment to answer, respondent asserts an addition to tax of $719,070.90 under section 66601 (valuation understatement).

After concessions by both sides, the issues are as follows:

(1) What the fair market value of decedent's 168,600 shares of Jung...

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