Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in the estate tax of the estate of Peggy Cook Cobb in the amount of $85,920.32.
Some of the issues raised by the pleadings have been disposed of by agreement of the parties leaving for our decision the following: (1) was the assessment and collection of a deficiency in estate tax barred by the statute of limitations...
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