MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined a deficiency in petitioner's estate tax of $126,885.
Decedent conveyed joint tenancies in three parcels of real property to his daughter severalyears before he died. The sole issue for decision is whether decedent's daughter contributed consideration equal to at least one-half of the total consideration that decedent and his spouse paid for the three parcels of real property...
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