Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioner's estate tax in the amount of $105,024.04.
The issues for decision are:
(1) Whether in determining the charitable deduction for amounts passing to residuary charitable legatees the preresiduary devise to an individual should be limited to the amount fixed by a settlement agreement made during the course of certain litigation or should be...
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