Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent determined deficiencies in the Federal estate tax of the Estate of Richard M. Frost, Deceased (the Estate) of $401,884, plus additions to tax of $200,942. Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for decision the following: (1) any part of the asserted deficiency in estate taxes is due to fraud; (2) whether the Estate is entitled...
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