Memorandum Findings of Fact and Opinion
NIMS, Chief Judge:
Respondent determined a $47,104.27 deficiency in petitioner's 1982 Federal estate tax and a $11,776.06 addition to estate tax under section 6651(a)(1). (Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect insofar as this case is concerned. All Rule references are to the Tax Court Rules of Practice and Procedure.)
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