MEMORANDUM OPINION
SWIFT, Judge.
Respondent determined a deficiency of $600,513 in petitioner's Federal estate tax.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect as of the date of decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After settlement of some issues, the issue remaining for decision is whether predeath transfers of decedent's property...
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