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ESTATE OF LEICHTER v. COMMISSIONER

Docket No. 2192-00.

85 T.C.M. 991 (2003)

T.C. Memo. 2003-66

Estate of Natalie M. Leichter, Deceased, Steven Leichter, Co-Special Administrator and Jeffrey L. Leichter, Co-Special Administrator v. Commissioner.

United States Tax Court.

Filed March 6, 2003.

Attorney(s) appearing for the Case

Walter Joseph Tribbey III, for the petitioner.

David R. Jojola, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined a $344,635 Federal estate tax deficiency for the Estate of Natalie M. Leichter (the estate). This deficiency derives from respondent's determination that the fair market value of Harlee International, Inc., a closely held corporation, was $2,718,358 instead of the $2,091,750 reported as its fair market value on the estate's tax return. The sole issue for our consideration is the...

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