Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in estate tax in the amount of $129,610.05.
Two issues are raised by the pleadings. (1) The determination that certain property transferred by the decedent to two irrevocable trusts constituted part of the taxable estate; and (2) the fair market value as of the date of decedent's death of Class A common stock of The Hobart Manufacturing Company.
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