The Commissioner determined a deficiency in estate tax in the amount of $36,819.33. The deficiency involved a number of issues, all of which have been adjusted between the parties by stipulation except one pertaining to the value of certain notes in the hands of the executor. The question presented is as to whether promissory notes given to the decedent in her lifetime by a maker who was insolvent just prior to the decedent's death but was a residuary legatee of the decedent...
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