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the stock". Estate of Andrews v. Commissioner, 79 T.C. 938, 956
(1982).
Petitioner must prove that respondent's determination of
value set forth in her notice of deficiency is incorrect. Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933); Estate of
Gilford v. Commissioner, 88 T.C. 38, 51 (1987). Respondent bears
the burden of proving the increases in the deficiency asserted in
her amended answer. Rule 142(a); Estate of Bowers v.
Commissioner, 94 T.C. 582, 595 (1990). Valuation is a question
of fact, and the trier of fact must weigh all relevant evidence
to draw the appropriate inferences. Hamm v. Commissioner, 325
F.2d 934, 938 (8th Cir. 1963), affg. T.C. Memo. 1961-347; Estate
of Newhouse v. Commissioner, supra at 217.
After considering the reports and testimony of both experts
and all the other evidence in the record, we think that neither
party has shown that the value of the interest received by Cyril
should be greater or less than the $43,878 determined by
respondent in her notice of deficiency. Accordingly, we hold
that petitioner is entitled to reduce the includable value of the
trusts by $43,878 pursuant to section 2043(a).
The final issue for decision concerns the fair market value
of a retail shoe store located in Louisville, Kentucky, as of
December 8, 1988, the alternate valuation date. Petitioner
valued the property at $150,980 on its estate tax return. In the
notice of deficiency, respondent valued the property at
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