Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined a deficiency of $18,493.00 in the estate tax of the Estate of Austin R. Silvester, and the estate has claimed an overpayment of tax. The issues remaining for decision are: (1) Whether any portion of the date-of-death values of certain real and personal property held by the decedent and his surviving spouse as joint tenants with rights of survivorship was attributable to consideration...
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