OPINION
TIETJENS, Judge:
The Commissioner determined deficiencies in estate tax for the taxable year 1964 in the amounts of $29,488.14 and $27,045.81, respectively, for the separate estates of Roger M. Chown and Harriet H. Chown, deceased.
The deficiencies were determined by including in the gross estates of both decedents $102,389.40, representing the proceeds of a life insurance policy owned by Harriet H. Chown and insuring Roger M. Chown...
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