Respondent determined a deficiency in estate tax in the amount of $572,530.08, based upon a number of adjustments, some of which are not in controversy here. The first question for determination is whether a trust created by decedent in her lifetime constituted a transfer in contemplation of death or a transfer intended to take effect in possession or enjoyment at or after her death, within the meaning of section 811 (c) of the Internal Revenue Code. The second question is...
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