MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge:
Respondent determined a deficiency of $1,373,797 in the Federal estate tax of the Estate of Eileen K. Brocato (petitioner).
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After a concession by respondent,
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