MOORE, Circuit Judge:
Estate of Amy Ann McGinnis Spalding, Deceased, Charles F. Spalding, Executor, Petitioner-Appellant, petitions this Court to review a decision of the United States Tax Court, Tannenwald, J., finding a deficiency in estate tax due from petitioner in the amount of $415,121.45. The case was presented to the Tax Court upon a stipulation of facts agreed upon by the parties. The tax in question resulted from the Commissioner's disallowance of...
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