Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined a deficiency in estate tax against the Estate of Don G. Gillum in the amount of $138,620.05 and that petitioners are liable for the deficiency as transferees of the estate. After concessions, the only issue remaining for decision is whether legal fees, accounting fees, and interest on the deficiency which are paid after the expiration of the period of limitation for assessment...
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