TIETJENS, Judge:
This proceeding involves a deficiency of $3,114.86 in the estate tax liability of the above named estate and, also, a claimed overpayment of $5,470.63 in estate taxes.
The question presented is whether respondent erred in determining the amount of $47,873.33 as the value of the charitable residue under decedent's will, allowable as a deduction for estate tax purposes.
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