Memorandum Findings of Fact and Opinion
WELLS, Judge:
Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $8,545,900. After concessions, the issue to be decided is the fair market value, as of September 19, 1986, of decedent's controlling interest in Gray Communications Systems, Inc. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at the date of decedent's death, and all Rule...
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