Memorandum Findings of Fact and Opinion
KERN, Judge:
The Commissioner determined deficiencies in docket No. 105653, in estate tax in the amount of $101,012.46, and a delinquency penalty in the amount of $25,253.12, against the estate of C. A. Seifert. The petitioners contend that most of the property included by respondent in the assets of the estate, were disposed of by the decedent prior to his death by gifts to his wife, son-in-law and daughter.
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