OPINION
MULRONEY, Judge:
Respondent determined deficiencies in the estate tax (docket No. 2757-64) and the 1961 income tax (docket No. 2758-64) of the Estate of Viola E. Bray, in the amounts of $175,294.07 and $19,434, respectively. All of the facts have been stipulated and are found accordingly.
The dockets were consolidated for trial and opinion and all of the issues have been resolved and disposed of by the parties with the exception of...
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