MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined a deficiency of $163,751 in the Federal estate tax of the Estate of James Barudin (decedent).
Unless otherwise indicated, all section references are to the Internal Revenue Code as of December 31, 1989, the date of decedent's death.
After settlement of some issues, the only issue for decision is the proper date-of-death value of decedent's ownership unit in a partnership...
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