OPINION.
MULRONEY, Judge:
The respondent determined a deficiency in estate tax of petitioner's estate in the sum of $27,248.53.
All of the facts are stipulated and they are found accordingly. The parties also stipulate that the sole issue for decision is: "Whether the 255 shares of common capital stock in Semmes Bag Company, Inc., having a value of $247,916.10, as bequeathed in Item V of the decedent's [Thomas J. Semmes] last Will and Testament...
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