OPINION
RAUM, Judge:
The Commissioner determined a deficiency in petitioner's estate tax in the amount of $23,555.90. Under the terms of her will, the decedent, Virginia Loren Ray, gave her residuary estate to her surviving husband on the condition that within 4 months after her death he execute and file in Probate Court a binding agreement in which he promised to bequeath property of equivalent value to their daughter and also undertook to make no...
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