Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined a deficiency of $480,447.46 in petitioners' estate tax.
As a result of concessions by the parties, the issues remaining for our decision are:
(1) whether certain gifts made on decedent's behalf by her conservators approximately four months prior to her death were made in contemplation of her death; and
(2) what was the fair market value, as of September...
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