Memorandum Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $875,304 in the estate tax of Ruth E. DuBois (decedent).
Other issues having been settled by the parties, the sole issue for decision is whether, at the time of her death, decedent owned the entire or only a one-third interest in a corporation.
All of the facts have been stipulated and are so found.
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