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Subsequent to these transfers, there were 71.703223 outstanding
shares of CamVic stock, which were owned as follows:
Shareholder No. of Shares Percentage Held
Ronald 17.9258 25
Cameron M. GC trust 17.9258 25
Kelly Long GC trust 17.9258 25
Ronald II GC trust 17.9258 25
Respondent refused to accept petitioners' $11,333.30 per-share
valuation of decedent's beneficial interest in 117.7568 shares of
CamVic stock as reported on Schedule G of the Federal estate tax
return. In the notices of deficiency in these cases, respondent
determined that the fair market value of the shares of CamVic stock
includable in decedent's gross estate was $75,278.22 per share.
Consequently, respondent increased decedent's gross estate in the
amount of $7,529,951.
OPINION
The only issue we address in this opinion is the effect, if
any, of CamVic's restrictive stock agreement on the value of the
CamVic stock includable in decedent's gross estate pursuant to
section 2036(a).
The gross estate includes the value of all property to the
extent of the decedent's interest therein at the time of his death.
Estate of Smith v. Commissioner, 108 T.C. ___, ___ (1997) (slip op.
at 11). The standard for valuation is fair market value, which is
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