Memorandum Opinion
GERBER, Judge:
This case is before the Court on petitioner's motion for summary judgment. The issue for our consideration is whether the terms of a buy-sell agreement control the valuation of shares of stock in a closely held corporation, at the date of death, for Federal estate tax purposes.
In his notice of deficiency dated June 28, 1984, respondent determined the value of the shares to be fair market value ($460,000) at the...
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