QUEALY, Judge:
The respondent determined a deficiency in the estate tax due from the Estate of Harry C. Jaecker, deceased, in the amount of $2,150,208.62. Petitioners claim an overpayment of estate tax in the amount of $70,265.50. The sole issue for determination is whether the remainder interests in three trusts established by the will of the decedent qualified for a charitable deduction pursuant to section 2055
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