Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in the Federal estate tax due from decedent's estate in the year 1953 in the amount of $2,160,256.47. The greater part of that deficiency and the only part here in issue results from respondent's determination that the fair market value of certain shares of corporate stock owned by the decedent at the date of her death was $2,367,008.10. Petitioner assigns that determination as error.
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