The respondent determined a deficiency in estate tax, in the amount of $758,649.32, and a delinquency penalty of $189,662.33. The petitioner claims that there has been an overpayment of tax and penalty.
The principal issue presented for consideration is whether assets located in the United States at the date of the decedent's death and held in the names of two foreign Stiftungs, including cash on deposit with two New York banks, are includible in the gross estate...
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