Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioner's estate tax in the amount of $3,642,528.60. The issues for decision are: (1) what was the fair market value on March 18, 1977, decedent's date of death, of decedent's 75.6 percent ownership, represented by 214,290 shares of common stock, of Oman Construction Co. (Oman Co.); and (2) whether an agreement reached between petitioner and respondent's Appeals...
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