Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent has determined a deficiency in estate taxes of $546,988.27.
The principal issue for decision is whether 18 promissory notes aggregating $722,500, given by Ava Ribblesdale to her son, Vincent Astor, gave rise to a valid claim against her estate, so as to be deductible from her gross estate under section 2053(a)(3) of the 1954 Code. By amended petition, petitioner raises two collateral...
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