Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined a deficiency in the petitioner's estate tax in the amount of $21,725.32. This proceeding was submitted under Rule 30 of the Court's Rules of Practice. The issues before the Court for decision are as follows:
(1) Whether the present value of the surviving spouse's right to receive $400 monthly for life pursuant to the terms of a prenuptial agreement is deductible by petitioner...
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