MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge.
Respondent determined a deficiency of $2,224,224.71 in the Federal estate tax of the Estate of Charles N. Aronson (decedent). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the date of decedent's death.
The sole issue for decision is whether an interest in the trust created by decedent's will qualifies for the estate tax marital deduction as...
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