Memorandum Findings of Fact and Opinion
QUEALY, Judge:
Respondent determined a deficiency in estate tax of petitioner in the amount of $255,236.09. All other issues having been resolved by agreement of the parties, the sole question remaining for determination is the fair market value as of the date of death of the decedent of 28,938 shares of First West Side Bank of Omaha, Nebraska, directly or indirectly owned by the decedent.
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