Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in estate tax of $148,428.28. By amendment to petition, petitioner alleged that the value of certain stock as reported in the estate tax return was overstated and on that basis claimed an overpayment. The issue for decision is the value at the date of Frederick P. Stratton's death of 211,973 shares of the common stock of Briggs & Stratton...
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