OPINION
TANNENWALD, Chief Judge:
Respondent determined a deficiency in petitioner's Federal estate tax of $7,296. After concessions, the sole issue to be decided is whether petitioner may deduct $3,000 from the date-of-death value of each of eight gifts made by Jane B. Ceppi, now deceased, on January 5, 1978, 10 days before her death.
This case was submitted fully stipulated pursuant to Rule 122.
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