Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined a deficiency in estate tax in the amount of $18,266.04. An additional deficiency was claimed in an amended answer. In reply thereto petitioner asserted a claim for overpayment of estate tax in the amount of $3,200.
The principal issue for decision (Issue I) is whether certain transfers of Sun Oil Company stock were made in contemplation of death within the meaning...
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