Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined a deficiency of $66,237.96 in the estate tax of the estate of Jack Robins Ensley. Because of concessions by petitioner, the only issue we must decide is what part of property jointly owned by decedent and his wife is properly includable in decedent's gross estate under section 2040, I.R.C. 1954.
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