MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge.
Respondent determined deficiencies in petitioner's Federal estate tax in the amount of $33,750 and generation-skipping transfer tax in the amount of $12,320.
All section references are to the Internal Revenue Code in effect as of the date of decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated.
After a concession,
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