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ESTATE OF SHARP v. COMMISSIONER

Docket No. 10241-91.

68 T.C.M. 1521 (1994)

T.C. Memo. 1994-636

Estate of Angeline V. Sharp, Deceased, Francis S. Pignone, Personal Representative v. Commissioner.

United States Tax Court.

Filed December 27, 1994.

Attorney(s) appearing for the Case

John A. Sanders, Allyson F. Creasman, and Keith J. Hesse, 111 N. Orange Ave., Orlando, Fla., for the petitioner. Francis C. Mucciolo, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge.

Petitioner is the Estate of Angeline V. Sharp (decedent). Respondent determined a deficiency in petitioner's Federal estate tax of $1,195,981. The issues for decision are:

(1) Whether the value of decedent's interest in a shopping center which she transferred to her children in 1982 is $193,000 as determined by respondent, or $136,250 as petitioner contends. We hold that the value of decedent...

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