Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent determined a deficiency of $51,509.22 in petitioner's estate tax and an addition thereto pursuant to section 6651(a) (1)
Due to concessions, the only issue presented for our consideration is whether petitioner's failure to file a timely Federal estate tax return and pay the amount shown as due on the return was...
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