RAUM, Judge:
The Commissioner determined that petitioner is liable as a transferee for an estate tax deficiency of $11,607.09 in respect of the estate of his deceased wife Margaret Black Bergman. Although the parties have reached agreement regarding several adjustments set forth in the notice of deficiency, there remain in controversy two adjustments as well as petitioner's liability as a transferee. In particular, the following questions are still unresolved...
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