Memorandum Opinion
KERN, Judge:
Respondent determined a gross deficiency in federal estate taxes in the amount of $495,800.87. Several issues have been settled as a result of concessions made by the parties. The only question remaining for our decision concerns respondent's determination that the "values for life insurance policies owned by decedent on the life of her husband * * * are based upon the actual proceeds of these policies." The values which had...
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