Memorandum Findings of Fact and Opinion
OPPER, Judge:
In this proceeding petitioner estate contests respondent's determination of a deficiency in estate tax of $43,028. Petitioner's decedent, Albert Patterson Humphrey (hereinafter referred to as decedent), died on February 23, 1942. Respondent, in his notice of deficiency, asserts as the bases for his deficiency determination four grounds: (1) that within two years of decedent's death, he and his wife made...
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