Estate of Leon Amiel, Deceased, Leon L. Amiel, Administrator, c.t.a. - Page 6

                                         -6-                                          
          pursuant to which:  (1) Ms. Barnett agreed not to seek probate of           
          the August 5 codicil; (2) Ms. Barnett would be paid $175,000; (3)           
          Ms. Barnett surrendered entitlement to any legacy in trust or               
          otherwise contained in the will or codicil; and (4) Ms. Barnett and         
          Hilda agreed to the division of certain personal property owned by          
          decedent which was in the possession of Ms. Barnett at the time of          
          decedent's death.                                                           
               Decedent's will and the August 18 codicil were admitted to             
          probate by the Surrogate's Court of Nassau County, New York.                
               The estate tax return was filed on January 2, 1990.  It                
          reported a total gross estate of $8,495,460.  The estate claimed a          
          marital deduction of $7,305,191, which consisted of $3,965,959 in           
          property interests not subject to a QTIP election and $3,339,231 in         
          property interests subject to a QTIP election.1  Respondent, after          
          making numerous adjustments that increased decedent's gross estate,         
          disallowed $1,701,372 of the claimed marital deduction.                     













               1    The $1 mathematical difference is due to rounding.                




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