Memorandum Findings of Fact and Opinion
WITHEY, Judge:
A deficiency in estate tax in the amount of $602.05 has been determined by the Commissioner against the petitioner. Petitioner claims an overpayment of estate tax in the amount of $26,516.55.
The issues for our decision are (1) whether respondent has erred in including the amount of $1,720.14 in the gross estate as the value of a chose in action for services rendered by decedent at the time of...
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