Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in estate tax. In his deficiency notice the respondent determined a deficiency of $445,356.14, and by his first amended answer increased the claimed deficiency to $457,082.19. By a second amendment to the answer to conform to proof, the respondent seeks the disallowance of an item of $2,500 as a debt of the estate previously allowed.
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