Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $320,978.60 in petitioner's Federal estate tax. Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect as of the date of death, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The issues for decision are (1) whether decedent held certain property in joint tenancy or as a contingent...
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