Memorandum Findings of Fact and Opinion
SWIFT, Judge.
Respondent determined a deficiency of $172,563 in the Federal estate tax of the Estate of Glen Climer (decedent) and additions to tax under section 6651(a)(1) in the amount of $37,175.
Unless otherwise indicated, all section references are to the Internal Revenue Code as of May 16, 1984, the date of decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure...
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