The respondent determined a deficiency in estate tax in the amount of $326,437.44. The petitioner contends that there is no deficiency and, further, that there has been an overpayment of estate tax.
The issues concern (1) the valuation of corporate stock owned by the decedent; (2) whether the decedent was engaged in business in the United States; and (3) whether an amount standing to the decedent's credit on the books of a domestic corporation is includible in the...
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