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ESTATE OF AMIEL v. COMMISSIONER

Docket No. 5602-93.

74 T.C.M. 239 (1997)

T.C. Memo. 1997-348

Estate of Leon Amiel, Deceased, Leon L. Amiel, Administrator, C.T.A. v. Commissioner.

United States Tax Court.

Filed July 29, 1997.

Attorney(s) appearing for the Case

John R. Morken and Joshua A. Hazelwood, Uniondale, N.Y., for the petitioner. Kevin J. Kilduff and Dante D. Lucas, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

Respondent determined a $2,504,100 deficiency in petitioner's Federal estate tax.

All of the 28 adjustments set forth in respondent's notice of deficiency have been resolved save one, that being the amount of the marital deduction to which the Estate of Leon Amiel, Deceased, (petitioner) is entitled. Petitioner contends that property that funded a residuary

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