Memorandum Opinion
FAY, Judge:
Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $114,760.04. The only issue presented is whether section 403(e)(3), Economic Recovery Tax Act of 1981, Pub. L. 97-34, 95 Stat. 305, precludes petitioner from qualifying for an unlimited marital deduction under section 2056.
The parties submitted this case fully stipulated pursuant to Rule 122. The stipulation...
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