QUEALY, Judge:
The respondent determined a deficiency in the Federal estate tax of the Estate of Sumner Gerard, deceased, in the amount of $4,111,906.38. Except for certain gifts by the decedent, the various issues have been disposed of by agreement of the parties. Consequently, the only issue remaining for decision is whether the transfer by the decedent on January 2, 1964, of 51 shares of stock in Aeon Realty Co., distributed in equal portions to his three...
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