MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge:
Respondent determined a deficiency of $696,554 in petitioner's Federal estate tax.
Unless otherwise noted, all section references are to the Internal Revenue Code in effect for the date of decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions, we must decide the fair market value of decedent's interest in five partnerships as of...
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