OPINION
CHABOT, Judge:
This matter is before us on respondent's motion for liquidation and distribution of collateral for satisfaction of liability secured by appeal bond.
The instant case deals with respondent's determination of deficiencies in Federal individual income taxes for 1975 and 1976 against Al J. Schneider and Agnes Schneider. After the trial of this case, Al J. Schneider (hereinafter sometimes referred to as decedent) died and...
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