MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined that petitioner has gift tax deficiencies of $3,189 for 1992 and $512,073 for 1993.
The issues for decision are:
1. Whether the fair market value in 1992 of Crossroads Insurance, Inc.'s stock that petitioner gave to his children was $628,619 ($704 per share), as respondent contends; zero, as petitioner contends; or some other amount. We hold that it was $303 per...
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