HENDRY, Judge.
In this appeal, appellant taxpayers attack the constitutionality of their 1970 tax assessment of certain shares of a closely held stock, owned by the parties in a family holding corporation not listed on an exchange and not regularly traded over-the-counter. Appellants attack any assessment of their stocks under § 199.051(2), Fla. Stat., F.S.A. (1969), which states:
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