Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined deficiencies in petitioner's estate and gift taxes and additions to tax as follows:
Docket No. 4833-64 Estate Tax ............... $52,351.02 Docket No. 2007-65 Additions to Tax Sec. 6651(a), I. R. C. 1954 and its Year Gift...
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