OPINION
CHABOT, Judge:
Respondent determined deficiencies in Federal gift tax against petitioners for the calendar quarter ended September 30, 1981, in the following amounts:
Docket No. Petitioner Deficiency 3146-85 Victor I. Minahan $882,737.74 3147-85 Marilee Minahan 882,737.93 3148-85 Estate of Mary M. Walter, deceased...
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