Memorandum Findings of Fact and Opinion
WELLS, Judge:
Respondent determined a deficiency in petitioner's Federal estate tax of $136,193.32. After concessions, the following issues remain for decision: (1) the value of two thoroughbred horses to be included in petitioner's gross estate, (2) whether $147,000 paid by petitioner pursuant to a "foal-sharing agreement" may be deducted as an administration expense, and (3) whether petitioner may deduct as administration...
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