OPINION
WITHEY, Judge:
The respondent, in docket No. 3379-68, determined an estate tax deficiency in the amount of $239,168.95 and addressed his notice to Estate of May L. Valentine, deceased, Lester Armour and T. Stanton Armour as coexecutors. In docket No. 3380-68, respondent determined a deficiency in the same amount against the May L. Valentine, June 6, 1932 Trust, Lester Armour and Patrick A.
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