MEMORANDUM OPINION
COHEN, Chief Judge:
Respondent determined a deficiency in the Federal estate tax of the estate of Evelyn M. McMorris (the estate) in the amount of $232,035. By amendment to the answer, respondent asserts an increased deficiency in the amount of $2,383,056.
After concessions, the issue for decision is whether the estate is entitled to deductions for (1) the portion of a Federal income tax liability to be refunded due to a reduction...
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