Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in income tax for the Estate of Louis Kamm, Deceased, and Emily E. Kamm for the year 1949, of $34,827.22. Respondent determined a deficiency in estate tax of $17,851.19 and a delinquency penalty of $4,462.80 under the provisions of section 3612(d)(1) of the Internal Revenue Code of 1939, against the Estate of Louis Kamm. Respondent also determined that Edythe Emily Kamm...
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