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ESTATE OF BROWN v. COMMISSIONER

Docket No. 13081-95.

73 T.C.M. 2655 (1997)

T.C. Memo. 1997-195

Estate of Paul E. Brown, Deceased, Peter D. Brown and Michael Brown, Co-Executors v. Commissioner.

United States Tax Court.

Filed April 28, 1997.

Attorney(s) appearing for the Case

James L. Malone III, Thomas C. Borders, and Carol A. Harrington, for the petitioner. James E. Kagy and Joseph P. Grant, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined a deficiency in petitioner's estate tax of $29,885,493.

Paul Brown was the chief operating officer of the Cincinnati Bengals from 1967 to 1991. In 1983, he sold 117 of his 118 shares of Bengals stock to John Sawyer, who owned 213 shares of Bengals stock. In exchange, Sawyer gave a $3.51 million note to Brown and sold an option to Brown's sons to buy up to 329 shares of Bengals...

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