The respondent determined a deficiency of $41,851.84 in the estate tax liability of the estate of Frank Mann, deceased. The petitioner claims an overpayment of estate tax.
The primary issue is whether or not the amounts of certain first mortgages on realty owned by decedent at his death are deductible in computing the decedent's net estate under section 812 (b) of the Internal Revenue Code.
The subordinate issue is, in the event that the first mortgages are...
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