MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge:
Respondent determined a deficiency of $127,304 in petitioner's Federal estate tax. Respondent filed an amended answer asserting an additional deficiency of $61,532.
Catherine E. Dowell (sometimes referred to as decedent or mother) owned 75 percent of the stock of Dowell Insurance Agency, Inc. (the stock or agency stock; the agency), at the time of her death. Decedent had previously sold 25 percent...
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