Memorandum Findings of Fact and Opinion
SMITH, Judge:
These proceedings, consolidated for hearing, are for the redetermination in Docket No. 2616 of a deficiency in estate tax claimed to be due from the estate of William C. Atwater in the amount of $223,362.27 and in Docket No. 2617 of the liability of the petitioner for the estate tax deficiency under section 811 of the Internal Revenue Code.
The questions in issue in Docket No. 2616 are whether...
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