The Commissioner determined a deficiency of $133,038.26 in estate tax. The only question for decision is whether the petitioner was a citizen of the United States within the meaning of section 802 of the Internal Revenue Code for Federal estate tax purposes.
The Government of Puerto Rico has filed a brief amicus curiae.
FINDINGS OF FACT.
The decedent died on July 21, 1944. The estate tax return was filed with the collector of internal revenue...
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