Memorandum Opinion
CLAPP, Judge:
Respondent determined a $674,540.19 deficiency in petitioner's estate tax. This matter is before the Court on respondent's Motion for Summary Judgment.
Petitioner has not submitted any data as required by section 20.2031-2(f), Estate Tax Regs., in connection with the issue of a blockage discount on the value of certain stock nor has she argued the issue in any answer, memorandum of law, or brief filed with respect...
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