OPINION.
BLACK, Judge:
The Commissioner has determined a deficiency in estate tax against the estate of Anna Floto de Eissengarthen in the sum of $2,345.38. Among the adjustments made by the Commissioner in the determination of this deficiency was adjustment (a), which is explained in the deficiency notice as follows:
It is held that the cash balance of $16,190.07 in a custodian account at Guaranty Trust Company, New York, New York, reported...
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