Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent determined a deficiency in the Federal income tax liability of Evelyn B. Price, deceased, for her 1976 calendar year in the amount of $17,985.90. Mrs. Price died prior to the issuance of the statutory notice of deficiency and petitioner, her estate, is represented by Dr. Larry R. Price, independent executor. The sole issue for decision is
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