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ESTATE OF MUELLER v. COMMISSIONER

Docket No. 2733-90.

107 T.C. 189 (1996)

ESTATE OF BESSIE I. MUELLER, DECEASED, JOHN S. MUELLER, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 5, 1996.

Attorney(s) appearing for the Case

Stevan Uzelac, Michael A. Indenbaum, and Paul L. Winter, for petitioner.

Thomas M. Rath and Trevor T. Wetherington, for respondent.

OPINION

RUWE, Judge:*

Respondent determined a deficiency of $1,985,624 in petitioner's Federal estate tax. Respondent's deficiency determination was primarily based on her assertion that the date-of-death value of shares of stock in the Mueller Co. was $2,150 per share, as opposed to $1,505 per share as reported on the estate tax return. The amount of the deficiency determined by respondent was the result of this increase...

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