OPINION
PARKER, Judge:
This matter is before the Court on respondent's motion for partial summary judgment, filed December 23, 1991.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect as of the date of the decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency of $14,014,749.30 in petitioner's Federal estate tax. The...
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