MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge:
Respondent determined a deficiency in petitioner's Federal gift tax for the 1992 taxable year in the amount of $170,885. The issue for decision is the fair market value of stock given by petitioner to her children and grandchildren.
Unless otherwise indicated, all section references are to the Internal Revenue Code as in effect for the year in issue, and all Rule references are to the Tax Court...
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