OPINION
SIMPSON, Judge:
The Commissioner determined a deficiency of $6,042,836.13 in the petitioner's estate tax. Due to concessions, the only issue remaining for consideration is whether certain charitable and marital gifts are to be charged with Federal estate and State death taxes. The resolution of that question turns on whether to give effect to an agreement providing that a "buy-sell" agreement should be set aside if the Commissioner disregards...
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