The respondent has determined a deficiency in estate tax in the amount of $142,477.71.
The sole issue herein concerns the value at which the decedent's interest in a partnership business is includible in his gross estate under the provisions of section 811 of the Internal Revenue Code.
Respondent has conceded that the decedent's estate is entitled to an additional deduction in the amount of $5,165.05 for 1947 income taxes and has stipulated with petitioners...
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