TIETJENS, Judge:
The Commissioner determined a deficiency in estate tax of $25,286.22.
The question for decision is whether 670 shares of common stock in the Zanesville Publishing Company owned by decedent at the time of his death subject to the terms of a certain contract between decedent and other stockholders should be valued for estate tax purposes at $200,000 as reported by the estate or at its fair market value $257,910.57 as determined by the...
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