Estate of Maddock v. Commissioner

OPINION.

ARundeul, Judge:

Respondent has determined a deficiency in estate tax in the amount of $142,477.71 based upon the determination that at the time of decedent’s death his partnership interest in Maddock and Company had a value of $566,905.38 rather than $256,085.38 representing the price received and the value reported in the estate tax return by the petitioners as the executors of decedent’s estate. Respondent attributes the greater value he has determined to the good will of Maddock and Company which he claims resulted from “such factors as longevity, established name, established…