Memorandum Findings of Fact and Opinion
OPPER, Judge:
By this proceeding petitioners challenge respondent's determination of a deficiency in estate tax in the amount of $74,237.42. This deficiency results in part from respondent's action in increasing the fair market value of property in the estate by the amount of $96,544.45; and in including in the estate the cash balances in three bank accounts, and the value of a one-fourth interest in a partnership...
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