HERSEY, Chief Judge.
Lewis E. Iandoli died testate in 1982, leaving one-half of his residuary estate to his wife, Angelina Iandoli (appellee), who was also named personal representative of the estate. The other one-half of the residuary was left to appellant, Marie Iandoli, decedent's daughter by a previous marriage. The will contained no provision for payment or apportionment of estate taxes.
Federal estate taxes of $1,111,151.00 came due in November 1982...
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