Memorandum Opinion
WHITAKER, Judge:
By notice of deficiency dated March 12, 1981, respondent determined a deficiency in petitioner's estate tax in the amount of $8,026.82. The sole issue for decision is whether or not the estate is entitled to deduct from the gross estate as an expense of administration a payment of $40,000 made in settlement of a will contest. For convenience our findings of fact and opinion are combined.
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