This case involves a deficiency in Federal estate tax determined by the respondent in the amount of $3,601.62. Petitioner assails respondent's inclusion of the entire community estate of Frank D. Neumann and his wife, Louise J. Neumann, in the estate of Frank D. Neumann, deceased, for tax liability under section 811 (e) (2), Internal Revenue Code, on the ground that only one-half of the community estate should be taxed for estate tax purposes, since the whole of such community...
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