Memorandum Findings of Fact and Opinion
BRUCE, Judge:
The respondent has determined deficiencies in gift taxes for the year 1954 in the case of petitioners as follows:
Paulina duPont Dean ....... $309,459.52 J. Simpson Dean ........... 319,793.37
The cases were consolidated for trial and will be considered together. The single issue presented is the fair market value per share
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