MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice dated July 11, 1994, respondent determined a deficiency in petitioner's estate tax in the amount of $271,031.37 and an accuracy-related penalty for negligence under section 6662(b)(1) in the amount of $42,763.25. All section references are to the Internal Revenue Code in effect as of the date of decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless...
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