The Commissioner has determined a deficiency in petitioner's estate tax of $21,150. The deficiency is due to an increase of $58,325.81 in the value of the stock in Sun Oil Company returned as part of decedent's gross estate. The adjustment is explained in the deficiency notice as follows: "The stock dividend of 831 shares at $70 3/16 per share of Sun Oil Company no par common stock is includible in gross estate for optional valuation purposes. Section 811(j), 1939 Code."...
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