OPINION
GOEKE, Judge:
This matter is before the Court on cross-motions for summary judgment under Rule 121(a).
Respondent issued a notice of deficiency in the Federal estate tax of the estate of decedent Doris F. Kahn (the estate), determining, among other adjustments, that the estate had undervalued two IRAs on the estate's Form 706, U.S. Estate (and Generation-Skipping Transfer) Tax Return. The issue before...
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