MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge:
Respondent determined a $998,508 deficiency in petitioner's 1996 Federal gift tax. The issue for decision is the fair market value of interests in a family limited partnership that petitioner transferred in 1996.
Unless otherwise indicated, all section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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