COHEN, Judge:
Respondent determined a deficiency of $531,534.97 in petitioner's Federal estate tax. The sole issue for decision is whether the surviving spouse's income interest in property constitutes "qualified terminable interest property" within the meaning of section 2056(b)(7) where the income interest is subject to the executor's election. Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect as...
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