SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined that the Estate of Marguerite S. Millikin (the estate) has an estate tax deficiency of $682,367 and that the Severance A. Millikin Trust B (Trust B) is liable for a generation-skipping transfer tax of $67,529. As then required by Estate of Park v. Commissioner, supra, we applied Ohio law to decide whether petitioners
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