SIMPSON, Judge:
The respondent determined a deficiency of $37,156.78 in the Federal estate tax of the Estate of Mary V. Rowan. The issues for decision are: (1) Whether a decree rendered by the Superior Court of California in a probate proceeding is conclusive as to what property interests were owned by the decedent for the purpose of Federal estate tax; (2) if such decree is not conclusive, then what, in our independent determination, were the property interests...
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