OPINION
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' Federal estate tax as follows:
Petitioner Amount Estate of Harry E. Draper, et al. ----------- $37,205.39 Estate of Elizabeth C. Draper, et al. ------- 58,272.92
The parties have settled all issues except whether the proceeds, a total of $78,345.68, of two insurance policies...
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