Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
In a notice of deficiency dated December 7, 1983, respondent determined a deficiency in petitioner's Federal estate tax in the amount of $45,921. The deficiency was based in part on respondent's increase in the value of the stock of J.W. Giselman Corporation held by decedent at the time of his death. In an amendment to his answer, dated July 24, 1985...
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