MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge:
Respondent determined a deficiency of $201,551 in Federal estate tax of the Estate of Theodore J. Chamberlain (decedent) and an accuracy-related penalty of $38,423 for negligence under section 6662(b)(1).
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at decedent's death, and all Rule references are
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