The Commissioner determined a deficiency in estate tax in the amount of $214,126.50. The decedent, Hedwig Zietz, was a nonresident alien of the United States and a resident of Switzerland at the time of her death. There were located in New York City when she died, securities having a substantial value. The deficiency results from the Commissioner's inclusion in Hedwig's estate for Federal estate tax under sections 811, 860, and 862, 1939 Code, of the entire value of the securities...
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