Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined a deficiency in the estate tax of the Estate of Saul A. Levine in the amount of $32,590.98.
Concessions have been made by both parties and the only issues remaining for our consideration are:
(1) Whether certain shares of stock in the name of the decedent at the time of his death were actually owned by his brother, and
(2) The value of certain claims...
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