MEMORANDUM OPINION
LARO, Judge:
In docket No. 1892-03, Estate of Claude C. Focardi, Deceased (decedent), Nina M. Focardi, Personal Representative, petitioned the Court to redetermine respondent' determination of deficiencies of $903,784 and $3,123 in the estate' Federal gift tax for 1996 and 1997, respectively. In docket No. 3130-03, Nina M. Focardi (Focardi) petitioned the Court to redetermine respondent' determination of deficiencies of $824,019 and $3...
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