Memorandum Opinion
STERNHAGEN, Judge:
The Commissioner determined an estate tax deficiency of $53,629.54, by including in decedent's gross estate the value of two trust estates created by the decedent and his wife.
The facts are stipulated.
[The Facts]
Thomas Neal died testate on October 5, 1940, a resident of Detroit, Michigan. Elizabeth M. Neal, his widow, is the executrix of his estate. The estate tax return was filed...
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