Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
By statutory notice dated July 13, 1987, respondent determined a deficiency in petitioner's estate tax of $96,371.06. By separate statutory notice of even date, respondent determined a deficiency in petitioner's gift tax for the calendar quarter ending March 31, 1974, in the amount of $22,226.86. The first issue is whether the agreement between Ila Jean Anderson and James R. Anderson to disregard the...
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