MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge:
Respondent determined a deficiency of $442,200 in petitioner's Federal gift tax for the taxable year 1992. After concessions, the sole issue for decision is the valuation of petitioner's gifts of shares of stock in Zip Sort, Inc., that he made to his children on December 31, 1992.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulations of fact are...
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