MILBURN, Circuit Judge.
Maxe Colleen McCorkle Morris appeals the tax court's decision that she owes additional taxes to the Commissioner of Internal Revenue Service ("Commissioner") based on the valuation of her deceased father's estate pursuant to the Internal Revenue Code of 1954, 26 U.S.C. § 2001 et seq. For the reasons that follow, we affirm.
I.
James B. McCorkle, decedent and father of petitioner, died testate on November 19, 1972...
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