OPINION.
TIETJENS, Judge:
The respondent determined a deficiency of $10,898.94 in estate tax. The petition alleges error in the respondent's computation of the gift tax credit allowable against the estate tax. All the facts are stipulated and the stipulation is incorporated by this reference.
The decedent, Frank B. Chapman, died May 17, 1951. The estate tax return was filed with the collector of internal revenue at Columbus, Ohio.
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