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ESTATE OF GIMBEL v. COMMISSIONER

Docket No. 21250-04.

92 T.C.M. 504 (2006)

T.C. Memo. 2006-270

Estate of Georgina T. Gimbel, Deceased, Janet G. Rogers, Joanne M. Gimbel, and Thomas W. Gimbel, Co-Executors and Co-Trustees v. Commissioner.

United States Tax Court.

December 19, 2006.

Attorney(s) appearing for the Case

Charles P. Rettig, Edward M. Robbins, Jr., Cory Stigile, and Lewis R. Walton, Jr., for petitioners.

Donna F. Herbert and Michael Zarefsky for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

SWIFT, Judge:

Respondent determined a $5,248,840 deficiency in the Federal estate tax of the estate of decedent Georgina T. Gimbel.

Unless otherwise indicated, all section references are to the Internal Revenue Code in effect on the date of decedent's death.

The only issue for decision is the fair market value of 3,601,267 restricted shares of the common stock of Reliance Steel and Aluminum Company...

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