Memorandum Findings of Fact and Opinion
PIERCE, Judge:
The respondent determined deficiencies in income tax, as follows:
Taxable Year Deficiency 1946 Estate of Gerald H. Smith, Deceased .................. $ 732.73 1947 Estate of Gerald H. Smith, Deceased .................. 39,493.87 1948 Virginia A. Smith and Estate of Gerald H. Smith ...... 10,470.56
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