OPINION
RAUM, Judge:
The Commissioner determined a $162,463.32 deficiency in petitioner's 1966 income tax. Pursuant to section 691(a) of the 1954 Code petitioner had reported a $632,402.84 long-term capital gain in his 1966 income tax return as income in respect of a decedent, and he had claimed a deduction of $439,856.99 under section 691(c) for estate taxes attributable to that item. Although the Commissioner treated section 691(c) as applicable...
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