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ESTATE OF LLOYD v. COMMISSIONER

Docket No. 5223-91.

71 T.C.M. 1903 (1996)

T.C. Memo. 1996-30

Estate of Willie C. Lloyd, Deceased, Iva Nell Holman, Executrix v. Commissioner.

United States Tax Court.

Filed January 29, 1996.

Attorney(s) appearing for the Case

Stewart R. Dudley, J. Birch Bowdre, Samuel H. Frazier, Elizabeth Ann McMahan, and Paul S. Leonard, Birmingham, Ala., for the petitioner. Linda J. Wise, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WRIGHT, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $1,275,416. After concessions, the sole issue remaining for our decision is the date-of-death value of decedent's one-half interest in two parcels of real estate held in trust.

FINDINGS OF FACT

Some of the facts have been stipulated and are found accordingly. The stipulation of facts and the attached...

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