Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined a deficiency of $21,708.45 in the Federal gift tax of each petitioner for the calendar quarter ending December 31, 1976. The issue is the value of certain stock in a closely held corporation.
Findings of Fact
Some of the facts have been stipulated and are so found. The stipulation and attached exhibits are incorporated herein by reference.
Petitioners...
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