The issues in the estate tax matter were: the fair market value of Frank DiSanto's (Frank) 186,177 shares (53.5%) of stock in Morganton Dyeing & Finishing Corp. (MD&F) on the date of death; the fair market value of the MD&F stock Grace DiSanto (Grace) was entitled to inherit from Frank's estate (a minority interest) on her date of death; whether Grace had expectancy interest only in the stock she was entitled to inherit; and whether Frank's estate was entitled to a marital deduction based on the value of the stock he willed to Grace or based on the value of the stock she was entitled to receive after executing a disclaimer of part of her interest in the stock.