Memorandum Findings of Fact and Opinion
RUWE, Judge:
Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $157,872.05. After concessions, the sole issue for decision is whether residential real property located at 704 Bayshore Drive, Tarpon Springs, Florida, is included in decedent's gross estate under section 2036(a).
Findings of Fact
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