Memorandum Findings of Fact and Opinion
TRAIN, Judge:
The respondent determined a deficiency in estate tax in the amount of $2,528.96.
The issues for decision are:
(1) The fair market value of the rights to produce a musical play and the rights to produce a motion picture based upon said musical play, based upon George Bernard Shaw's play, "Pygmalion" as of the date of death of decedent, Gabriel Pascal, July 6, 1954; and
(2) The fair...
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