FAY, Judge:
Respondent determined a deficiency of $108,583.54 in Federal estate taxes. We must decide if a legacy bequeathed to the decedent by his wife, Ethel G. Hoenig, and renounced by his executors subsequent to his death, is includable in his gross estate for purposes of the Federal estate tax.
FINDINGS OF FACT
Certain facts have been stipulated and are so found.
Edward E. Hoenig, the decedent, died a resident of New York, N.Y...
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