OPINION
COHEN, Judge:
Respondent determined a deficiency of $516,365.63 in petitioners' Federal estate tax. In an amendment to answer, respondent also asserted an additional deficiency of $58,678.62. The issues for decision are: (1) Whether gift tax paid by the donees of net gifts made within 3 years of decedent's death is includable in decedent's gross estate under section 2035(c);
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