Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $61,573 in petitioner's Federal estate tax. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect as of the date of decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions, the issue for decision in this case is the value of property owned by Dominick A. Necastro...
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