MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge.
By notice of deficiency dated March 9, 1994, respondent determined a deficiency in, and additions to, petitioner's estate tax as follows:
Additions to Tax --------------------------------- Deficiency Sec. 6653(a)(1) Sec. 6651(a)(1) $359,822 $17,991 $89,956
Unless otherwise indicated, all section...
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