Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $101,588.09. Several issues having been settled, the issues remaining for decision are: (1) whether the withdrawals by the petitioner of certain amounts from a joint bank account in the names of himself and the decedent constituted gifts from the decedent to himself; and (2) assuming gifts did not result, whether these...
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