Memorandum Findings of Fact and Opinion
HARRON, Judge:
The respondent has determined a deficiency in estate tax in the amount of $4,496.29.
The issue is whether one-half of property, securities, which were held in the name of the decedent at the time of his death was owned at and prior to his death by his wife, Bessie Leavitt, so that the value of such property properly was omitted from the value...
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