OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $1,112,253.63 in estate tax. The case has been presented on stipulated facts which settle all of the issues but one. The stipulations are adopted as the findings of fact.
The estate tax return was filed with the collector of internal revenue for the twenty-third district of Pennsylvania.
The only question upon which the parties disagree is whether the 2 per cent Pennsylvania...
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