Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Petitioner is the Estate of Rula Brinton Flake. Respondent determined a $1,150,822 deficiency in petitioner's Federal estate tax. The issue for decision is whether Rula Brinton Flake's (decedent's) interests in two trusts that passed to her husband upon her death qualify for the marital deduction under section 2056. We hold that they do.
Section references are to the Internal Revenue Code in...
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