Memorandum Findings of Fact and Opinion
KERN, Judge:
Respondent, under date of January 17, 1945, determined a deficiency in Federal estate tax of petitioners in the amount of $1,028.485.15. By far the greater part of this deficiency arose from respondent's determination that "decedent had a taxable interest in one-half of the remainder of the residuary estate of Max E. Bernheimer, subject to the life estate" of the primary beneficiary, resulting in an addition...
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