MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge:
Respondent determined a deficiency of $616,768.49 in petitioner's Federal estate tax. After concessions, the issues for decision are: (1) Whether the value of property in which Anna Soberdash (hereinafter decedent) held a qualified income interest for life and for which a deduction was allowed under section 2056(b)(7)
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