MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
Respondent has determined a deficiency in Federal estate tax of $1,837,266 and an accuracy related penalty of $367,453. Respondent's determination of a deficiency relates primarily to her determination that certain property was the separate property of decedent John Kenly (decedent) at the time of his death and was not community property. As a result of concessions made by respondent, the only issue...
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