OPINION
BRUCE, Judge:
Respondent determined a deficiency of $635,005.87 in the estate tax liability of the Estate of George E. P. Gamble. Practically all of the deficiency results from respondent's including in the value of the gross estate of the decedent an amount paid by the decedent as California State gift taxes, for which, subsequent to his death, the State allowed a credit against California State inheritance taxes.
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