Respondent has determined a deficiency in the estate tax of $69,327.87 against the executors of the estate of Clotilde Santiago Rivera who died on January 9, 1949. Respondent explains the deficiency in his 30-day letter dated April 19, 1951, which is incorporated in the deficiency notice as follows:
The deficiency here results principally from computing the tax liability on the estate of a citizen and resident of Puerto Rico as that of a nonresident not a citizen...
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