Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined a deficiency of $184,863 in petitioners' 1976 Federal income tax. Due to concessions by both parties, the issues remaining for our decision are: (1) the fair market value of an office building and real property located in Eureka, California as of March 19, 1976; (2) the fair market value of shares in a closely-held corporation as of December 1976;...
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