MEMORANDUM OPINION
KORNER, Judge:
By notice of deficiency dated August 15, 1994, respondent determined a deficiency in the estate tax of the Estate of Anne F. Greco, deceased, in the amount of $24,276.53. By stipulation of the parties, the case was submitted under Rule 122.
All statutory references are to the Internal Revenue Code in effect as of the date of decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure...
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