BEGHE, Judge:
Respondent determined a deficiency of $215,075 in petitioner's Federal estate tax and an addition to tax of $43,015 under section 6651(a)(1) for late filing of the Federal estate tax return.
Unless otherwise noted, all section references are to the Internal Revenue Code in effect as of the date of Herbert R. Cavenaugh's death, and all Rule references are to the Tax Court Rules of Practice and Procedure. All references to petitioner are...
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