GRANT, J.
The plaintiff's testator was, at the time of his death in 1973, the owner of a substantial block of the common stock of a publicly held corporation. On April 5, 1977, the Commissioner of Corporations and Taxation, acting under the provisions of G.L.c. 65, § 25 (as amended through St. 1971, c. 555, § 58), valued the stock at $3,507,823 for purposes of the inheritance tax.
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