STEPHENS, Circuit Judge.
The estate of J. Leslie Vogel, deceased, pending in the California Probate Court, has petitioned us for review of a decision of the tax court approving a deficiency determination made by the Commissioner. The principal question is whether or not all of the property left by the decedent, plus certain property standing in his wife's name, was community property. The Commissioner and the tax court have held that it was.
I.
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