MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
Respondent determined deficiencies in Bonnie I. Barge's Federal gift tax for 1987 and 1988 in the amounts of $5,547,988 and $4,000, respectively. Respondent also determined an addition to tax under section 6660 in the amount of $1,664,396 for 1987. Respondent has since conceded that no addition to tax under section 6660 is due. We accept that concession...
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