OPINION
RAUM, Judge:
The Commissioner determined a deficiency in estate tax against the estate of Lydia G. Maxwell (decedent) in the amount of $141,991. Decedent was born on June 2, 1902, and resided in Old Brookville, New York, at the time of her death on July 30, 1986. At the time the petition was filed, First National Bank of Long Island had its legal address in Woodbury, New York, and Victor C. McCuaig, Jr., had his legal address in Glen Cove...
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