MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined a deficiency of $175,801 in the estate's estate tax.
Decedent's husband, George Robert Hughes (Bob Hughes), founded Bob Hughes Motors, Inc., d.b.a. Advance Leasing (Advance Leasing). Bob Hughes died in 1996. Winifred Hughes (decedent) was the sole owner of the stock of Advance Leasing from 1996 until she died in 1999. After Bob Hughes died, Dean McBride (McBride) became...
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