Memorandum Opinion
GERBER, Judge:
Respondent determined a deficiency of $226,228 in petitioner's Federal estate tax liability. After concessions, the sole issue for decision is whether, under Tennessee's elective share statute and other related State probate statutes, the surviving spouse's calculated elective share must be reduced by a proportionate share of decedent's secured debts in determining petitioner's maximum allowable marital deduction.
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