The respondent determined a deficiency in estate tax in the amount of $1,538.69, to which he added a 25 per cent penalty in the amount of $3,367.55 under the provisions of section 3612 (d) (1) of the Internal Revenue Code. The respondent disallowed deduction of $10,802.40 which was taken on the return as executors' commissions. The pleadings raise the issue whether the respondent erred in disallowing deduction of the above sum; but the dispute between the parties relates...
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