MEMORANDUM OPINION
COHEN, Judge:
Respondent determined Federal gift tax deficiencies for 1994 in Docket No. 469-00 in the amount of $126,080 and in Docket No. 470-00 in the amount of $137,953.
The issue for decision in these consolidated cases is whether a successor annuity interest of a spouse in a retained two-life annuity is a qualified interest that is subject to valuation pursuant to section 2702. Unless otherwise indicated, all section references...
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