MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice of deficiency dated August 31, 1995, respondent determined a $947,049 deficiency in petitioner's estate tax and a $189,410 accuracy-related penalty for negligence. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect as of the date of the decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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