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their stock interests lacked sufficient similarity to
E's interest to serve as a proper measure of value.
David J. Duez, Matthew P. Larvick, James J. Morrissey, and
Kevin J. Feeley, for petitioners.
John Q. Walsh, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioners petitioned the Court to
redetermine a Federal estate tax deficiency of $1,038,257.
Following concessions, we must decide the fair market value of
the subject stock on April 14, 1994. Respondent determined that
the fair market value was $70.79 per share. Petitioners argue
that the fair market value was $29.77 per share. We hold that
the fair market value was $56.50 per share. Unless otherwise
stated, section references are to the Internal Revenue Code as
applicable herein, and Rule references are to the Tax Court Rules
of Practice and Procedure. References to decedent are to Alice
Friedlander Kaufman, and references to the estate are to
decedent's estate. Percentages are rounded to the nearest one-
hundredth. Monetary amounts are rounded to the nearest penny.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits submitted therewith are
incorporated herein by this reference. Decedent died on
October 14, 1993, at the age of 78, while a resident of
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