FEATHERSTON, Judge:
Respondent determined that each petitioner is liable as transferee for a deficiency of $9,949.74 in the Federal estate tax of the Estate of Stella M. Wilson. The questions presented for decision are:
(1) Whether on the date of Stella M. Wilson's death she was the owner of a contract right entitling her to collect $234.25 in accrued interest from her grandson;
(2) Whether Stella M. Wilson made completed gifts to her two adult...
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