MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge:
Respondent determined a deficiency of $756,564 in petitioner's Federal estate tax.
The issues for decision are: (1) Whether the fair market value of 12,889 shares of Savings Bank of Mendocino County (Savings) on the date of decedent's death was $300 per share as respondent determined in the notice of deficiency; $181.50, as petitioner reported on its estate tax return; or some other amount. We...
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