Memorandum Findings of Fact and Opinion
WILLIAMS, Judge:
The Commissioner determined a deficiency in petitioner's Federal estate tax in the amount of $1,465,823.00.
The issues the Court must decide are: (1) whether certain real estate is includible in decedent's estate, (2) if so, the value of that property, (3) whether special use valuation, section 2032A,
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