Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined a deficiency in estate tax in the amount of $52,452 and an addition to tax under section 6651(a)(1) in the amount of $13,052. The issues for decision are whether petitioner is entitled to claim a deduction of $171,324 from decedent's gross estate, and whether petitioner is liable for an addition to tax for failure to file timely the estate tax return. We hold that petitioner is not...
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