OPINION
RAUM, Judge:
Petitioner is the Estate of Alexander S. Bowers. The Commissioner determined deficiencies in the decedent's income tax for the calendar years 1982 and 1983 in the amounts of $43,211.42 and $216,851, respectively. The decedent was a resident of Virginia, and Robert M. Musselman, executor of his estate, was also a resident of Virginia when the petition herein was filed. After concessions, the parties agree that the only remaining...
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