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ESTATE OF PROCTOR v. COMMISSIONER

Docket No. 10462-92.

67 T.C.M. 2943 (1994)

T.C. Memo. 1994-208

Estate of Foy Proctor, Deceased, First National Bank of Amarillo, Independent Executor, Petitioner, Beth Hays, Clynice Baker, and Texas Tech University, Intervenors v. Commissioner.

United States Tax Court.

Filed May 11, 1994.

Attorney(s) appearing for the Case

Thomas H. Cantrill, 1445 Ross Ave., Dallas, Tex., and Andrius Kontrimas, for the petitioner. Donald P. Lan, Jr., Jack M. Kinnebrew, Rowland Foster, 901 Main St., Dallas, Tex., and Thomas L. Burdett, for intervenors Beth Hays and Clynice Baker. William R. Cousins III, Robert Don Collier, and Robert M. Bolton, 901 Main St., Dallas, Tex., for intervenor Texas Tech University. Henry C. Griego, for the respondent.

Memorandum Findings of Fact and Opinion

WELLS, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $4,323,330. Petitioner is the Estate of Foy Proctor (decedent). After concessions by the parties,1 the primary issue for decision is whether petitioner is entitled to a charitable deduction for the Channing Ranch and, if so, the amount of such deduction. In deciding that issue, we must resolve...

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