Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined a deficiency in decedent's Federal estate tax in the amount of $400,450 and an addition to tax under section 6660 in the amount of $120,135. The deficiency was due to an alleged undervaluation of decedent's interest in a land trust partnership.
After concessions, the issues for decision are:
(1) The fair market value on August 27, 1986, of decedent's interest in...
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