Memorandum Findings of Fact and Opinion
HALPERN, Judge:
Respondent has determined deficiencies in both estate tax and gift taxes, and additions to tax in connection with the gift taxes, against petitioner Estate of Cecil Rosenblatt, Deceased, Roberta Schreiber Ulmer, Hannah Goldstein, and Iris Gruenebaum, Administratrices, C.T.A. (the Estate). Respondent has also determined that petitioners Roberta Schreiber Ulmer (Roberta) and Marvin Rosenblatt (Marvin...
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