Estate of Marcia P. Hoffman, deceased, Elisabeth Hoffman, Personal Representative - Page 41

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          profits earned by WLI for 1991 and 1992 did not need to be                  
          accounted for in his valuation analysis.  Because respondent has            
          failed to establish a fair market value above the amount reported           
          on the estate tax return, we hold for the estate on this issue.             
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          

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