Memorandum Findings of Fact and Opinion
LARO, Judge:
This case is before the Court pursuant to a petition filed on behalf of the Estate of Maria Proios to redetermine respondent's determination of a $220,255 deficiency in its Federal estate tax liability and an $89,074 addition thereto under section 6651(a)(1). Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year of death. Rule references are to the Tax Court...
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