MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined a deficiency of $337,474 in the Federal estate tax of the Estate of decedent Lieselotte Kohlsaat.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for June 5, 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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