MEMORANDUM OPINION
WELLS, Judge:
Respondent determined a $764,472 deficiency in the estate tax of the Estate of Marie A. Maniglia (the decedent). The issue we must decide is whether the entire value of certain real property or only 50 percent of the value of that property is properly includable in the decedent's gross estate. All section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice...
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