Memorandum Findings of Fact and Opinion
WHALEN, Judge:
Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $3,334,435 and an addition to tax under section 6651(a)(1) in the amount of $333,443.50. All section references are to the Internal Revenue Code as amended, unless stated otherwise.
After concessions by the parties, there are two issues for decision. The principal issue is the fair market value of certain stock...
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