MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge:
Respondent determined a deficiency in petitioner's Federal estate tax of $2,465,624 and an accuracy-related penalty of $477,113 for negligence under section 6662(b)(5).
Unless otherwise noted, all section references are to the Internal Revenue Code in effect at decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions, including respondent...
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