MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined a deficiency of $1,809,921 in the Federal estate tax of the Estate of Decedent Sam Homer Marmaduke.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect as of September 7, 1993 (the date of decedent's death or the valuation date), and all Rule references are to the Tax Court Rules of Practice and Procedure.
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