The Commissioner determined a deficiency in estate tax in the amount of $7,385.64. Petitioners claim a $5,318.70 overpayment.
The question presented is whether decedent's obligation to pay $14,000 to his daughter after his death, assumed in exchange for his daughter's release of his son from an indebtedness in a like amount, was "contracted bona fide and for an adequate and full consideration in money or money's worth" as is required for a deductible claim for estate...
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