MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
By notice of deficiency dated April 16, 1999, respondent determined a deficiency in Federal estate tax of $5,427,983. Of the adjustments giving rise to that determination, the only one remaining in dispute is respondent's increase in the value of certain shares of stock included in the gross estate.
Unless otherwise noted, all section references are to the Internal Revenue Code in effect at...
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