McLAUGHLIN, Circuit Judge.
The taxpayer estate seeks review of a decision of the Tax Court which found a deficiency.
The material facts are not in dispute. Decedent died on May 29, 1954 a resident of Philadelphia County, Pennsylvania. Her husband, William, died on January 18, 1937 a resident of Delaware County, Pennsylvania. Prior to his death, he had acquired under his mother's will and by purchase 107 parcels of land located in Philadelphia and Delaware...
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