Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined a deficiency of $15,329.69 in the estate tax of the Estate of Nolan N. Foster. The sole issue remaining for decision is whether the Commissioner erred in determining that the deduction claimed on the estate tax return for the decedent's community one-half of the net excess of liabilities accrued over progress payments received with respect to a certain construction project...
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