OPINION
KERN, Judge:
The respondent has determined a gross deficiency in Federal estate taxes in the amount of $129,113.77 and a net deficiency of $69,016.76 upon allowing additional credit for State death taxes allowable if substantiated in the amount of $60,097.01.
Petitioner does not contest any of the adjustments in decedent's taxable estate made by respondent in his "Statement" attached to
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