Memorandum Opinion
COHEN, Judge:
Respondent determined a deficiency of $755,912 in petitioner's Federal estate tax. After a trial in which petitioner contended unsuccessfully that certain real property was community property passing to a qualified terminable interest trust, by various pending motions, petitioner attempts to assert a claim that such property passed to decedent's surviving spouse as joint tenancy property, eligible for the marital exclusion...
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