MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge:
Respondent determined a deficiency of $522,710 in petitioner's Federal estate tax. We must decide the value of Helen J. Smith's shares of stock in two companies, Jones Farm Inc. (JFI), and First National Bank of Waverly (FNBW), as of her death on January 25, 1993. When she died, Helen J. Smith (decedent) held one-third of the stock of JFI and 12 percent of the stock of FNBW.
Unless otherwise noted...
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