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Estate of DiSanto v. Commissioner

Docket Nos. 10344-97, 21951-97.

78 T.C.M. 1220 (1999)

T.C. Memo. 1999-421

Estate of Frank M. DiSanto, Deceased, Roxanne DiSanto Tinnell, Byrnadette DiSanto, and Frank DiSanto, CoExecutors v. Commissioner. Estate of Grace J. DiSanto, Deceased, Roxanne DiSanto Tinnell, Byrnadette M. DiSanto, and Frank R. DiSanto, CoExecutors v. Commissioner.

United States Tax Court.

Filed December 27, 1999.

Attorney(s) appearing for the Case

W. Curtis Elliott, Jr., Paul M. Hattenhauer, and William R. Culp, Jr., for the petitioners. James E. Gray and Paul G. Topolka, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined deficiencies in estate tax of $4,362,142 for the Estate of Frank M. DiSanto (Mr. DiSanto), and $3,791,104 for the Estate of Grace J. DiSanto (Mrs. DiSanto).

Mr. DiSanto owned a controlling block of 186,177 shares (53.5 percent) of the stock in Morganton Dyeing & Finishing Corp. (MD&F) when he died on November 26...

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