TANNENWALD, Judge:
The Commissioner determined a deficiency in estate tax in the amount of $1,476,958.71. The petition alleges that the tax was overpaid in the amount of $81,025.58.
Prior to trial of the case, the parties executed an agreement of partial settlement, under which they made various settlements, concessions, and agreements respecting several of the issues raised by the pleadings — with the result that the amount of tax in controversy...
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