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ESTATE OF RENIER v. COMMISSIONER

Docket No. 2976-98.

80 T.C.M. 401 (2000)

T.C. Memo. 2000-298

Estate of James J. Renier, Deceased, Kent K. Renier and Dubuque Bank & Trust Company, Co-Executors v. Commissioner.

United States Tax Court.

Filed September 25, 2000.

Attorney(s) appearing for the Case

James L. Malone III and Sheri L. Everson, for the petitioner. James S. Stanis and David S. Weiner, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GALE, Judge:

Respondent determined a deficiency in Federal estate tax of $326,382.08 and an addition to tax under section 6662(a) of $64,471.42 against the Estate of James J. Renier (estate).

After concessions, we must decide the following:

1. What was the fair market value of the 22,100 shares of stock in the Renier Company held by James J. Renier (decedent) at his death on April 10, 1994 (valuation...

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