JONES, Judge.
The issue involved in these tax proceedings is whether the value of the interest of plaintiffs' decedent in a trust at the date of his death should have been included in his gross estate for estate tax purposes under the provisions of section 302 (d) of the Revenue Act of 1926, 44 Stat. 9, 71, 26 U.S.C.A.Int.Rev.Acts, page 228. Two trusts are involved, one created in 1924 and another in 1928. The issue turns on whether the trust created in 1928 constituted...
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