OPINION
STERRETT, Judge:
The respondent determined a deficiency in the Federal estate tax of the Estate of Howard O. Wood, Jr., in the amount of $20,388.88. There are two questions presented for our decision. The first is whether the income tax liabilities of the Estate of Caryl Hackstaff Wood should be allowed as a deduction to reduce the value of the interest of the present decedent, Howard O. Wood,
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