The tax liability involved in Docket No. 19480 is for estate tax deficiency in the amount of $840,467.79. In Docket No. 20519, there is involved transferee liability for the same deficiency. The proceedings were consolidated for hearing, and it was stipulated at the hearing that if it be determined in the principal proceeding there is a deficiency in the estate tax, there will be a corresponding liability in the transferee proceeding.
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