MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge:
Respondent determined a deficiency in petitioner's Federal estate tax of $238,515.05, which by subsequent amendment to the answer was increased to $1,100,000. After concessions, the sole issue remaining for decision is the fair market value of 492,610 shares of stock in Dunn Equipment, Inc. (Dunn Equipment), owned by Beatrice Ellen Jones Dunn (decedent) on the date of her death, the valuation date. Unless...
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