This proceeding involves an estate tax deficiency in the amount of $21,810.20. At the hearing the respondent filed an "Amendment to Answer" in which he prays for a deficiency of $32,587.87 instead of the deficiency originally determined.
As shown in a statement attached to the deficiency notice, the deficiency results from the "inclusion in the gross estate for the reason that the joint owner has not established contribution" of five items of jointly owned property...
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