OPINION
KÖRNER, Judge:
In his notice of deficiency, respondent determined that the Estate of Thomas G. Slater (decedent) was liable for an estate tax deficiency of $149,163. After concessions by both parties, we must decide whether gifts of stock in a corporation owning a family farm, given by decedent to his sons within 3 years of his death, should be included in and taxed as part of decedent's gross estate or ...
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