MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
Respondent determined a $716,355 deficiency in petitioner's Federal estate tax. The parties have agreed to the fair market value of certain property included in the estate before the application of any discount, but they disagree about the amount of any such discount.
FINDINGS OF FACT1
Ruth J. Casey, decedent, was domiciled in California at the time...
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