Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined a deficiency of $274,120 in the estate tax of petitioner Estate of Anthony J. Frank, Sr. (hereafter referred to as petitioner Anthony's estate). Respondent determined a deficiency of $390,461 in the estate tax of petitioner Estate of Margaret E. Frank (hereafter referred to as petitioner Margaret's estate).
The issues for decision are: (1) Whether 91 shares of common stock...
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