Memorandum Findings of Fact and Opinion
SMITH, Judge:
This proceeding is for the redetermination of an estate tax deficiency of $48,824.39. The questions in issue are whether there were deductible gifts to charity of (1) the remainder interest of an inter vivos trust which the decedent created during his lifetime, naming his sister as life beneficiary with remainder over to charities; and (2) the remainder interests of several testamentary trusts...
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