Memorandum Findings of Fact and Opinion
DISNEY, Judge:
This proceeding involves a deficiency in estate tax determined by the Commissioner in the amount of $7,644.99. Two issues are presented for decision. The first is whether certain transfers made by decedent in his lifetime were made in contemplation of death; the second is whether the Commissioner erred in disallowing a deduction of the alleged present value of certain gifts in remainder passing under...
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