- 36 -
is the case here, the record falls short of the standard which we
require, we are left to decide the case against the party who has
the burden of proof. Because petitioners bear the burden here,
we sustain respondent's determination, as modified by concessions
in brief. We hold that the fair market value of the estate's
stock was $56.50 per share on the applicable valuation date.
We have carefully considered all arguments, and, to the
extent not discussed above, find them to be irrelevant or without
merit. To reflect the foregoing,
Decision will be entered
under Rule 155.
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