Memorandum Findings of Fact and Opinion
The Commissioner originally determined a deficiency in petitioner's estate tax in the amount of $52,611.86, and thereafter, in an Amendment to Answer, he claimed an increased deficiency of $276,697.29, or a total of $329,309.15. The issues are (1) whether the decedent had a half interest in a partnership which allegedly owned certain real estate which was includable in her gross estate and (2) whether the decedent in any event...
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