MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge.
Respondent determined a deficiency of $261,950 in petitioner Johann Hess's Federal gift tax for taxable year 1995. Respondent also determined a deficiency of $261,950 in petitioner Johanna Hess's Federal gift tax for taxable year 1995. The issue for decision is the fair market value under section 2501
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