SteReett, Judge: Respondent determined a deficiency in petitioner’s Federal estate tax return in the amount of $66,112.02 and a delinquency penalty under section 6651(a), I.R.C. 1954, 1 in the amount of $13,222.40. The issues for our determination are: (1) Whether an issue as to the validity of a debt of the decedent, Ahos Anthony Horvath, is befor…
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