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ESTATE OF AMLIE v. COMMISSIONER

Dkt. No. 16039-02.

91 T.C.M. 1017 (2006)

T.C. Memo. 2006-76

Estate of Pearl I. Amlie, Deceased, Rodney B. Amlie, Executor v. Commissioner.

United States Tax Court.

April 17, 2006.

Attorney(s) appearing for the Case

Robert E. Dallman, Michael G. Goller, and Robert B. Teuber, for petitioner.

James E. Schacht and Mark J. Miller, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GALE, Judge.

Respondent determined a Federal estate tax deficiency of $360,266, and an accuracy-related penalty under section1 6662(a), with respect to the Estate of Pearl I. Amlie (the estate).2 After concessions, the issues remaining for decision are:

(1) The fair market value of First American Bank Group, Ltd. (FABG) stock held by Pearl I. Amlie ...

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