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a]óDecisions affd agreement amount annuity apply apportioned apportionment statute appraisal beneﬁciaries beneﬁt bequest claim closely-held Code Commissioner Commr corporation court held date of death death taxes dece decedentís death decedentís estate decedents dying decision deﬁciency determined distribution district court election estate tax return executor F Supp fair market value Favor of Apportionment federal estate tax ﬁduciary ﬁle ﬁled ﬁling ﬁrst generation-skipping transfer tax gift tax gross estate gross income included income in respect income tax inheritance taxes inter vivos trust interest IRC Section legatees Ltr Rul marital deduction ment NE2d paid payable payment percent personal liability prior probate qualiﬁed heir real estate real property received refund residuary estate residue Rev Rul Revenue Ruling Schedule Service share special use valuation speciﬁc surviving spouse tate tax burden tax clause Tax Court taxpayer tion transfer usrc USTC