Memorandum Opinion
OPPER, Judge:
This is a related proceeding to that in Seattle Trust and Savings Bank, 22 T. C. — [Dec. 20,558], decided this day. There respondent determined a deficiency as transferee resulting in an alleged liability for estate tax and penalty of this petitioner, against which, as original taxpayer, respondent has determined deficiencies in estate tax and penalty which were here put in issue of $353,095.05 and $176,547...
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