OPINION
NIMS, Chief Judge:
Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $143,327.
The issue for decision is whether section 403(e)(3) of the Economic Recovery Tax Act of 1981, Pub. L. 97-34, 95 Stat. 305 (ERTA), precludes petitioner from qualifying for an unlimited marital deduction under section 2056. (Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and...
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