Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $384,284 in petitioner's Federal estate tax. The issue for decision is whether petitioner is entitled to a deduction under section 2056 for decedent's interest in certain community property that was placed in a trust. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect as of the date of decedent's death.
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