MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge:
Respondent determined a deficiency of $103,932 in petitioner's Federal estate tax and an addition to tax pursuant to section 6651(a)(1) of $25,983. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect on the date of the death of Joseph G. Maltaman (decedent), and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the sole...
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