Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $152,279.37 in petitioner's Federal estate tax. After concessions by petitioner, the issue for decision is whether we should follow a state court's reformation of decedent's trust instrument, purporting to grant retroactively to the surviving spouse a general power of appointment over the trust property, for purposes of determining petitioner's estate tax marital...
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