OPINION
SCOTT, Judge:
The Commissioner determined a deficiency in Federal estate tax of the Estate of Jeanne Lepoutre, deceased, in the amount of $84,295.54. Petitioner, the administrator of the estate, was a resident of Brooklyn, New York, at the time of the filing of the petition in this case. The estate tax return of Jeanne Lepoutre's estate was filed with the district director of internal revenue, Hartford, Conn.
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