MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice dated January 17, 1995, respondent determined a deficiency in petitioner's estate tax of $118,709.31. 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. After concessions, the sole issue for decision is whether petitioner, pursuant to section 2053(a)(2), is entitled...
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