Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The respondent determined a deficiency in estate tax in the estate of William G. Miller, Deceased, in the amount of $11,376. The only issue is whether the attorney fee for the administrator's attorney, which was allowed and paid in the sum of $50,000 was deductible in full or in the sum of $17,000, which respondent determined.
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