Memorandum Findings of Fact and Opinion
HARRON, Judge:
Respondent determined a deficiency in estate tax in the amount of $78,316.40. Petitioners have agreed to the adjustment made by respondent with respect to the fair market value of certain stock owned by decedent at the time of his death. The only question remaining in this proceeding is whether the value of the corpus of a trust created by decedent in 1922 should be included in his gross estate under...
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