United States Tax Court.
MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined a deficiency of $2,275,040 in the Federal estate tax of the Estate of W. Clyde Wright (decedent).
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect on April 20, 1990, the date of decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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