Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined a deficiency in decedent's Federal estate tax in the amount of $164,811.68. The sole issue for decision is whether the decedent was a resident of the United States under the estate tax provisions at the time of his death.
Findings of Fact
Some of the facts have been stipulated and are found accordingly.
Edouard H. Paquette (hereinafter decedent) died on...
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