MEMORANDUM OPINION
HAMBLEN, Judge:
Respondent determined deficiencies in O.D. McKee's gift tax in the amounts of $918,879 and $16,737 for the periods ending December 31, 1988 and 1990, respectively. Respondent determined a deficiency in Anna Ruth McKee's (decedent) gift taxes in the amount of $918,879 for the period ending December 31, 1988. Respondent further determined a deficiency in decedent's estate's Federal estate taxes in the amount of $1,257,057...
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