Memorandum Findings of Fact and Opinion
HAMBLEN, Judge:
Respondent determined a deficiency of $84,445 in the Federal estate tax liability of the estate of Richard J. Hatchett. The issues to be decided are 1) the fair market value of decedent's residence; 2) the fair market value of decedent's farm land; 3) whether petitioner has established its entitlement under section 2040(a)
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