Memorandum Findings of Fact and Opinion
BEGHE, Judge:
Respondent determined a deficiency of $1,985,624 in petitioner's Federal estate tax. The sole issue for decision is the date-of-death fair market value of the 8,924 shares of common stock of the Mueller Co. (the Company) included in the gross estate of Bessie I. Mueller (decedent).
Findings of Fact
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