OPINION.
BLACK, Judge:
This proceeding involves the determination of a deficiency of $49,620.32 in estate tax. The deficiency is due to several adjustments made by the respondent to the net estate of the decedent as disclosed by the estate tax return. All of these adjustments are small except one. This latter one is the only one contested and represents an addition to the value of the gross estate of two "Transfers...
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