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KOSMAN v. COMMISSIONER

Docket No. 27091-93.

71 T.C.M. 2356 (1996)

T.C. Memo. 1996-112

Jane O. Kosman v. Commissioner.

United States Tax Court.

Filed March 11, 1996.

Attorney(s) appearing for the Case

James M. Bausch, Larry A. Holle, Lincoln, Neb., and Terry R. Wittler, for the petitioner. Albert B. Kerkhove, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined that petitioner Jane O. Kosman has gift tax deficiencies of $158,136 for 1986 and $15,157 for 1987.

The issue for decision is the fair market value of Kosman, Inc., stock that petitioner gave to her children on September 30, 1986, and March 31, 1987. To decide the value of that stock, we must decide the following issues:

(1) The value of Kosman, Inc.'s 12,834 shares...

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