Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent has determined a deficiency in estate tax against the petitioner in the amount of $1,165,993.90. The parties have settled certain issues and the only question remaining for decision is whether petitioner is entitled to deduct as an administration expense $490,292.89 of sales commissions paid in connection with the sale of decedent's collection of books, pamphlets, broadsides; maps, and similar...
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