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the value of the shares on John's date of death, the evidence in
the record of such value is scant. The John Appraisal, which
postulated the $44.65 per-share value on John's date of death
contended for by petitioner, is not in the record. Its
conclusions are in the record only because they are stated in the
Decedent Appraisal. Moreover, the John Appraisal was performed
by RPR, whose valuation methodologies are considered in some
detail elsewhere in this opinion. Because we conclude infra that
there are substantial flaws in the methodology employed by RPR to
value the Johnco stock on decedent's date of death, which
produced a significantly understated estimate of value, we
likewise do not believe that RPR's valuation of the stock as of
John's date of death is reliable. Accordingly, the evidence in
the record strongly supports the conclusion that the $44.65 per-
share value contended for by petitioner is too low.
More significantly, we do not believe that John, as
testator, contemplated that the requirement in his will that the
unified credit bequest be funded with Johnco shares "as * * *
valued by independent appraisal" as of his date of death would
result in the use of different date-of-death values for the
Johnco stock--one for purposes of the estate tax return for
John's estate and the other for purposes of funding the unified
credit bequest. Such a construction of the will would put John's
estate's marital deduction in jeopardy, because shares eligible
for the section 2056 marital deduction on the basis of the
valuation used on the return would--if a different, lower
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