These proceedings were brought for a redetermination of a deficiency in estate tax of $176,335.33. Petitioners claim an overpayment of $2,680.05. The primary litigated issue is whether respondent erred in disallowing as a deduction under Internal Revenue Code, section 812, a claim against the estate, representing a part of a note on which decedent was designated as maker.
The case was submitted upon a stipulation of facts and evidence adduced at the hearing. Those...
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