OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $10,280.19 in estate tax. The only issue for decision is whether he erred in disallowing a deduction of $85,725.86 claimed on the return for previously taxed property under section 812 (c) of the Internal Revenue Code. The case has been submitted on a stipulation of facts.
Anna C. Yantes, the decedent, died intestate a resident of Melbourne, Florida, on November 20, 1950...
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