MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined a deficiency of $3,509,857 in the Federal estate tax of the Estate of decedent Ann H. Brookshire.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect as of November 20, 1993, the date of decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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