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accountant, Mr. Lippert, "that he was changing his estate
plan to take advantage of the unlimited marital deduction"
and led Mr. Lippert "to believe that * * * [the decedent]
had instructed Attorney Clark to change his Will so that it
would qualify for the unlimited marital deduction."
Petitioner also argues that the decedent told Mrs. Rapp
that "when he died everything would be hers" and that the
decedent told his niece, Mrs. Josephson, that "whatever he
earned in his lifetime was going to be his wife's, and
ultimately his sons[']."
As "indirect evidence" that the decedent intended the
residue of his estate to qualify for the marital deduction,
petitioner argues in its post-trial brief that the decedent
told his wife, his son, and his banker, Mr. Bruce Bell,
"that his estate plan had been drafted to avoid or defer
taxes, and that there would be minimal taxes due upon his
death." Petitioner also cites as indirect evidence the
decedent's statements made to Mrs. Josephson, his
investment adviser, Mr. Parneet Kongkeo, and his friend,
Mr. John Pabigian, about "the importance of estate planning
and deferring taxes." Petitioner further cites the fact
that the decedent had shown "an article to his CPA
discussing the marital deduction and the changes in the
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