Memorandum Findings of Fact and Opinion
Respondent determined a deficiency of $4,476.82 in estate tax and a 25 per cent addition to tax for failure to file a timely return. The issues are (1) the fair market value of certain properties owned by decedent at the time of his death, (2) whether payment of decedent's unpaid pledge to a charity entitles his estate to a deduction in determining the value of the net estate, and (3) whether petitioner's failure to file a...
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