Memorandum Findings of Fact and Opinion
HARRON, Judge:
The respondent determined originally that there is a deficiency in estate tax in the amount of $73,782.48. In an amended answer, the respondent has made claim for increase in the deficiency in the amount of $2,337.01, pursuant to section 871(e) of the Internal Revenue Code.
The increase in the deficiency is due to the discovery by the executors after the filing of the estate tax return of an...
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