MEMORANDUM OPINION
LARO, Judge:
The Estate of Pauline Welch (the estate) petitioned the Court to redetermine respondent's determination of a deficiency in the amount of $59,987 in its Federal estate tax. Following concessions by both parties, the remaining issue is whether the estate is entitled to discount the value of stock for built-in capital gains tax liability. Unless otherwise stated, section references are to the Internal Revenue Code in effect as...
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