Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined a deficiency of $7,396,001.95 in the Federal estate tax of the estate of Samuel A. Agnew. All issues have been settled by the parties except one. The sole issue for decision is how much, if any, of the executor's fee paid to Samuel Jay Agnew is deductible as an administration expense for estate tax purposes.
Findings of Fact
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