Memorandum Findings of Fact and Opinion
SWIFT, Judge:
Respondent determined a deficiency in petitioners' Federal estate tax liability of $3,223,785 for 1981. The sole issue remaining for decision is whether, under the California apportionment statute, the amount of the Federal estate tax deduction claimed with respect to a charitable residuary bequest should be reduced to reflect a share of the Federal estate liability.
Findings of Fact
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