Memorandum Findings of Fact and Opinion
PIERCE, Judge:
Respondent determined a deficiency in estate tax against the Estate of Carrie H. Cowan, in the amount of $13,345.14.
The issues for decision are:
(1) Whether a $70,000 indebtedness to the decedent by her son that arose from his purchase of her interest in a business, was forgiven by the decedent prior to her death, so that if it was not a transfer in contemplation of death it is not includable...
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