MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
Respondent determined a deficiency in Federal estate tax liability of $2,951,937. The sole issue remaining for decision is the value of certain shares of stock that Frederick Carl Gloeckner (decedent) owned on the date of his death. All section references are to the Internal Revenue Code in effect at the time of decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure...
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