MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge.
Respondent determined a $45,241 deficiency in estate tax for Earl C. Koester's estate (the estate). After a timely petition was filed, respondent conceded the $45,241 estate tax deficiency. Following this concession, the estate argues that the $109,270 estate tax liability it originally reported on its estate tax return was incorrect. The estate, contending that decedent was deprived of equal protection...
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