Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
The Commissioner determined a deficiency in the estate tax of petitioner in the amount of $7,438.31.
The sole question for our decision is whether $30,000 in currency in a safe deposit box in an envelope bearing the name of decedent's wife in his handwriting should, as the Commissioner has determined, be included in decedent's gross estate under
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