MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
Respondent determined a deficiency in Federal estate tax of $1,489,660. The adjustment giving rise to the deficiency is on account of respondent's increase in the value of certain shares of stock (and an option to acquire additional shares of stock) included in the gross estate. Petitioner has assigned error to that adjustment, and we must decide the value of those shares.
Unless otherwise noted...
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