Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
Respondent determined a deficiency in the 1959 income tax of petitioner estate in Docket No. 2750-64 in the amount of $15,207.23 and in the 1959 income tax of petitioners in Docket No. 2751-64 in the amount of $27,494. The two dockets were consolidated for trial, briefing and opinion.
The pertinent question is the value of a claim which the...
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