MEMORANDUM OPINION
WELLS, Chief Judge.
Respondent determined a deficiency in the Federal estate tax of the Estate of Ralph H. Davis (estate) in the amount of $220,593. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect on the date of death of Ralph H. Davis (decedent), and all Rule references are to the Tax Court Rules of Practice and Procedure. The issue to be decided in the instant case is whether the interest...
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