Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $134,278.17 in the Federal estate tax of petitioner.
The issues for decision are:
(1) To what fractional interest discount is petitioner entitled in connection with its 50-percent undivided interests in two parcels of real property; and
(2) whether 100 percent of the proceeds of three whole life insurance policies should be included in petitioner...
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