Memorandum Opinion
ARUNDELL, Judge:
The Commissioner determined a deficiency in estate tax of $39,413.72 and in his answer makes claim for a total deficiency of $78,508.31. Petitioners claim in their amended petition an overpayment of $25,538.32. A stipulation filed by the parties at the hearing has the effect of wiping out any deficiency and disclosing a substantial overpayment of tax. The only question for us to decide, therefore, is whether the amount...
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