Memorandum Opinion
WILBUR, Judge:
Respondent issued a notice of deficiency to petitioner on July 15, 1977, in which he determined a deficiency in estate tax in the amount of $71,327.18. Petitioner filed a timely petition with this Court on October 8, 1977. Estate of Bernard W. Pechan, Deceased, Bernard Warren Pechan, Administrator v. Commissioner, Docket No. 10341-77. The parties subsequently reached a basis of settlement by agreeing that petitioner...
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