MEMORANDUM OPINION
LARO, Judge:
Anthony J. Frese (Frese), acting in his capacity as executor of the Estate of Kwang Lee and with a mailing address in Hackensack, New Jersey, petitioned the Court to redetermine respondent's determination of a Federal estate tax deficiency of $1,020,129, a section 6662(a) accuracy-related penalty of $204,026, and a section 6651(a)(1) addition to tax of $255,032 for untimely filing.
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