Memorandum Findings of Fact and Opinion
HARRON, Judge:
The respondent determined a deficiency in estate tax in the amount of $4,039.86. There are two issues: (1) Whether the fair market value on the valuation date, August 28, 1962, of 233 payments to be made by Seagrave, under an employment contract, was $121,576.78, as determined by the respondent, or $85,900 as claimed by the petitioner. (2) Whether the fair market value on August 28, 1962, of several...
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