Memorandum Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $12,164.64 in the Federal estate taxes of the Estate of Corinne Allen Shepherd (decedent). After concessions, the sole issue for decision is whether the property interest passing to decedent's surviving spouse is a terminable interest and therefore does not qualify for the marital deduction.
All of the facts have been stipulated, and the stipulation of facts and the attached...
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