NIMS, Judge:
Respondent determined a Federal estate tax deficiency in the amount of $144,980 with respect to the Estate of Hon Hing Fung (the estate). The issues for decision are:
(1) Whether a one-half interest owned by Hon Hing Fung (decedent) in certain real property must be included in his gross estate at its full value of $442,500, or whether the property may be included at its net equity...
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