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lating the price for each of decedent's respective stock inter-
ests in B&W Brownsville, B&W Harlingen, B&W Mission, B&W Austin,
and B&W Finance, the parties to the FNFS transaction added to the
book value of each of those companies a premium of 23 percent of
the trade notes receivable that were held by each such company at
the time of that transaction.
On or about August 7, 1992, the estate filed Form 706,
United States Estate (and Generation-Skipping Transfer) Tax
Return (estate tax return). In that return, the estate listed
the value of 100 percent of the stock of B&W Longview as $2
million and claimed a value of $1 million for decedent's 50-
percent stock interest in that corporation.
On or about November 17, 1993, the estate filed an amended
estate tax return (amended estate tax return) in which the estate
listed the value of 100 percent of the stock of B&W Longview as
$1,452,000 and claimed a value of $726,000 for decedent's 50-
percent stock interest in that corporation. Respondent treated
the amended estate tax return as a claim for refund and denied
it.
OPINION
Respondent determined in the notice of deficiency, inter
alia, that on the valuation date the fair market value of dece-
dent's 50-percent stock interest in B&W Longview was $1,251,460.
Respondent modified that determination and claims on brief that
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