Memorandum Opinion
SIMPSON, Judge:
The Commissioner determined a deficiency of $82,245.00 in the Federal estate tax of the Estate of Luigi Biagioni. After a concession by the petitioner, the only issue to be decided is the value, at the date of the decedent's death, of a claim brought by the decedent in the California courts for flood damage to his property.
All of the facts have been stipulated, and those facts are so found.
The decedent...
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