Rehearing and Rehearing In Banc Denied September 28, 1987.
OPINION OF THE COURT
BECKER, Circuit Judge.
This appeal in a tax refund case concerns the correct valuation for federal estate tax purposes of 54,000 shares of stock subject to certain legally binding, nonassignable stock options granted to the children and grandchildren of decedent, Ruth H. Dorn. The district court found that the shares should be included in the gross estate at the option...
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