WILLIAMS, Judge: The Commissioner determined a defi* ciency in the Federal estate tax due from the estate of Samuel I. Newhouse in the amount of $609,519,855. The Commissioner also determined an addition to tax for fraud pursuant to section 6653(b) 1 in the amount of $304,759,927. The Commissioner has conceded the addition to tax for fraud. <p "b210-8" pgmap="210(51) 211(…
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