Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $233,927.
After concessions, the sole issue for decision is whether the will of Lillian J. Lewis requires that the residuary estate satisfy the Federal estate tax liability. We hold that it does.
All section references are to the Internal Revenue Code as in effect at the date of decedent's death, unless...
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