MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge.
Respondent determined an estate tax deficiency in the amount of $347,219, all of which is in dispute. The following three issues are in controversy: (1) Whether the reported value of a partially completed personal residence should be increased to reflect its value if completed because of the possibility of insurance recovery or reimbursement; (2) whether, in connection with the same residence, the gross...
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