Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined an estate tax deficiency of $3,661,955.31. Petitioner asserts an overpayment of estate taxes in the amount of $2,213,941. To resolve the differences between petitioner and respondent, we must determine the value, on Helen Baker Jenner's death, of 226,800 shares of Baker Fentress & Co. (hereinafter BF) stock included in her estate. We must also determine the value at the time...
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