Memorandum Findings of Fact and Opinion
QUEALY, Judge:
On or before October 27, 1963, a U.S. estate tax return was duly filed on behalf of decedent's estate showing a taxable estate in the amount of $748,534.91 and a net estate tax payable of $209,477.54.
In his notice of deficiency, the respondent determined that the corrected taxable estate of the decedent amounted to $5,838,621.48, on account of which there was a deficiency in estate tax of $2...
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