Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined a deficiency of $3,853,445 in petitioner's Federal estate tax. Concessions having been made by the parties, the sole issue remaining is the fair market value as of the alternate valuation date of 37,500 Class B shares of SMC Shipping Corporation stock, includible in decedent's gross estate by virtue of section 2036.
Findings of Fact
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