Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined a deficiency of $75,272 in petitioner's Federal estate tax. After concessions, the only issue for decision is whether petitioner may deduct, as a claim against the estate under section 2053(a)(3), payments made to several charitable organizations and individuals pursuant to promises made by decedent before his death. We hold that it may not.
References to decedent are to...
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