Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
The Commissioner determined a deficiency in the estate tax of petitioner in the sum of $23,447.28.
The two issues here presented for our decision are:
(1) Was the fair market value of 3,515.56 acres of land in Gonzales County, Texas, belonging to decedent's estate and known as the "Bailey Farm", on October 25, 1949, $45 per acre, as determined...
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