Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined a deficiency of $22,827.32 in the estate tax liability of the petitioner. The issues remaining for our decision are: (1) Whether the real estate comprising the Hotel Mayfair property should be fully included in decedent's gross estate; (2) whether the personal property there should be so included; (3) whether the real estate comprising the El Patio property should be so included...
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