OPINION.
OPPER, Judge:
Respondent determined a deficiency in estate tax of $125,580.69, based on a number of adjustments of which only one now remains in controversy. An overpayment of $14,791.55 is claimed. The single issue relates to the valuation of seven survivorship annuities taken out by decedent during his life. All of the facts have been stipulated and are hereby so found. The estate tax return was filed with the collector for the third district...
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