OPINION
WILBUR, Judge:
Respondent determined a deficiency in petitioner's Federal gift tax for the calendar quarter ended March 31, 1974, in the amount of $9,599.72. Respondent further determined a deficiency in petitioner's Federal estate tax in the amount of $48,087.52. By way of amended answer, respondent claimed an increase of $8,493.46 in the proposed Federal estate tax deficiency, making the overall estate tax deficiency $56,580.98.
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