Estate of Thomas L. Kaplin, Deceased, Maury I. Kaplin, and Gertrude F. Kaplin, Surviving Spouse v. Commissioner of Internal Revenue

BOYCE F. MARTIN, Jr., Circuit Judge.

The petitioners appeal a decision of the Tax Court upholding a deficiency in their taxes of $379,255 in 1975 and $3,115 in 1976. The Tax Court’s decision is reported as Estate of Kaplin v. Commissioner, Tax Ct.Mem.Dec. (P-H) ¶ 82,440 (1982). The petitioners assert in this appeal that: (1) the Tax Court’s findings are clearly erroneous; (2) the Tax Court applied the wrong legal standard in valuing certain property; and (3) the Tax Court should have reopened the record to allow the introduction of evidence of the subsequent sale of the property-

The alleged…