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ESTATE OF FORBES v. COMMISSIONER

Docket No. 24492-97.

81 T.C.M. 1399 (2001)

T.C. Memo. 2001-72

Estate of Augusta Porter Forbes, Deceased, Frederick W. Orr, Jr., Executor, v. Commissioner.

United States Tax Court.

Filed March 23, 2001.

Attorney(s) appearing for the Case

J. Nelson Irvine, Chattanooga, Tenn., Bruce C. Bailey, and John P. Cowart, Jr., for the petitioner.

John W. Sheffield III, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

THORNTON, Judge:

Respondent determined that petitioner is liable for a $1,665,230 deficiency in Federal estate tax and a $222,332 penalty under section 6662(g) for a substantial estate tax valuation understatement.1 The issues for decision are: (1) The fair market value at the date of decedent's death of undivided fractional interests in two parcels of real property held in a qualified...

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