Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in estate tax in the amount of $88,034.58. The great bulk of all the decedent's assets comprising his gross estate as reported in the estate tax return was listed therein as jointly owned with his brother, Joseph Montanio. The principal question is whether the Commissioner erred in including the full value of such property in the gross estate rather than one-half thereof as reported...
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