Memorandum Opinion
WRIGHT, Judge:
Respondent determined a deficiency of $416,477.62 in petitioners' Federal estate tax. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect as of the date of decedent's death. All Rule references are to the Tax Court Rules of Practice and Procedure. The issues for decision are:
(1) Whether the surviving spouse's interest in a trust constitutes qualified terminable interest...
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