OPINION
TANNENWALD, Judge:
Respondent determined a deficiency of $358,872.49 in petitioner's Federal estate tax. Other items having been settled by the parties, the sole issue remaining for decision is whether certain U.S. Treasury bonds of a type redeemable at par value in payment of estate tax liabilities were includable in decedent's gross estate at their par value rather than their fair market value at the date of death.
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