MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge.
Respondent determined a deficiency of $17,910,408 in the Federal estate tax of the estate of decedent Josephine T. Thompson and a $7,164,163 accuracy-related penalty under section 6662(a).
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect on May 2, 1998, the date of decedent's death, and all Rule references are to the Tax Court Rules of Practice and...
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