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class A voting stock from the reported $47,700 (or $2,650 per
share) to $14,435,907 (or $801,994.83 per share) and increased the
value for the 3,942.048 class B nonvoting stock from the reported
$10,446,427 (or $2,650 per share) to $14,134,213 (or $3,585.50 per
share). These values resulted in the following determined
increases to decedent's gross estate:
Amount Amount Increases
reported by determined by to gross
the estate respondent estate
18 shares of
class A voting
shares $47,700 $14,435,907 $14,388,207
3,942.048 shares
of class B
nonvoting shares 10,446,427 14,134,213 3,687,786
Total disputed increases 18,075,993
On brief, respondent concedes that the values of decedent's
class A and class B shares do not exceed $11,090,094 and
$13,887,007, respectively.
In addition, respondent decreased the amount of the marital
deduction from the reported $15,127,237 to $1,723,437, because of
(1) respondent's redetermination of the fair market value of the
class A voting stock and (2) the resulting estate tax consequences
which are to be borne by that portion of the estate (the residue)
passing to decedent's surviving spouse. And finally, respondent
determined that petitioner is liable for $7,057,554 in penalties
pursuant to section 6662(a), (g), (h)(1) and (2)(C).
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