IRWIN, Judge:
Respondent determined a deficiency of $87,077.02 in petitioner's estate tax.
The issues presented for our consideration are: (1) Whether promissory notes held by decedent but which were extinguished upon his death are includable in his gross estate; (2) if the notes are includable in decedent's estate, the fair market value of the notes; and (3) whether respondent should allow a credit against the Federal estate tax for $5,653.15 paid...
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