Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined a $259,651.81 deficiency in petitioner's Federal estate tax and a $64,912.95 addition to tax under section 6651(a)(1) for failure to timely file a return. Respondent also determined that petitioner improperly applied the special use valuation reduction of section 2032A. Petitioner concedes that respondent's determination regarding the special use valuation is correct and that petitioner...
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