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MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: Respondent determined a deficiency in
Federal estate tax of $1,489,660. The adjustment giving rise to
the deficiency is on account of respondent’s increase in the
value of certain shares of stock (and an option to acquire
additional shares of stock) included in the gross estate.
Petitioner has assigned error to that adjustment, and we must
decide the value of those shares.
Unless otherwise noted, all section references are to the
Internal Revenue Code as in effect at the time of decedent’s
death, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
FINDINGS OF FACT
Some facts have been stipulated and are so found. The
stipulation of facts filed by the parties and the accompanying
exhibits are incorporated herein by this reference. Some of
respondent's proposed findings of fact have been conceded by
petitioner and, accordingly, are so found.1
1 In part, Rule 151 provides as follows:
RULE 151. BRIEFS
* * * * * * *
(e) Form and Content: * * *
* * * * * * *
(3) * * * In an answering or reply brief, the party
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Last modified: May 25, 2011