OPINION
COHEN, Judge:
This case has been submitted fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and Procedure. The stipulation of facts is incorporated herein by this reference. Walter H. Geiger (decedent) died a resident of Allegany County, Md., on May 7, 1977. Petitioners are the duly appointed and qualifying personal representatives of the estate of decedent and resided at LaVale, Md., at the time the petition herein was filed...
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