WILBUR, Judge:
Respondent determined a deficiency in estate tax of $163,526.54 against petitioner, the Estate of James E. Curry. Concessions having been made by both parties, the remaining issue for our decision is whether the value of the decedent's interest in certain contingent legal fees pertaining to litigation still in progress as of the date of death should be included in his estate under section 2033.
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