OPINION
DAWSON, Judge:
Respondent determined a deficiency of $9,320.01 in the petitioner's Federal estate tax. Petitioner has claimed an overpayment of $1,050. Counsel fees and miscellaneous expenses incurred in this proceeding will be determined in connection with the Rule 50 computation.
The only issue presented for decision is whether the amount of $34,581.71 claimed as the decedent's personal debt obligation to his surviving spouse under...
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