Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $105,696 in petitioner's Federal estate tax. After a stipulation of settled issues, the remaining issues for decision are: (1) Whether property reported on Schedule A of petitioner's Federal estate tax return was properly included in the gross estate, (2) whether the transfer of certain property by decedent to his daughter was partly a gift and partly a sale or, alternatively...
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