MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
Respondent determined that there should be an increase in the reported value of certain real property resulting in a $1,974,500 Federal estate tax deficiency. Petitioner disagrees with respondent's value determination and also contends that the value reported on the estate tax return was overstated and that the estate should be entitled to a refund due to an overpayment of estate tax. We consider here...
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