Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined deficiencies in the estate taxes of petitioners as follows:
Petitioners Deficiencies Estate of Donald M. Hayes .. $ 73,577.98 Estate of Ruby Hayes ....... 108,767.79 ___________ Total ................... $182,345.77 ===========
The sole issue to be decided is the...
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