In the instant cases respondent has determined that petitioners are liable as transferees for a deficiency in estate taxes determined against the estate of Louise H. Parker, of which estate petitioners are distributees. In the petitions filed herein the petitioners allege that there is no deficiency of estate tax due from the transferor estate, and also allege that there has been an overpayment of estate tax by the transferor. On brief petitioners concede that an overpayment...
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