OPINION
NIMS, Judge:
In this case, respondent determined a $5,784,910 Federal estate tax deficiency and a $1,156,982 addition to tax under section 6662(b)(1). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at decedent's date of death, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions, the sole remaining issue for decision is whether certain securities...
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