Respondent, in his notice of deficiency, determined that the decedent's estate should be increased by $59,014.74, resulting in a deficiency in estate tax in the amount of $20,118.24 to account for decedent's one-half community obligation for principal and accrued interest totaling $118,029.49 on a promissory note dated December 1, 1949, executed in favor of the decedent and Virginia Tiffany as trustees for their children under a declaration of trust dated July 9, 1942.
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