Memorandum Findings of Fact and Opinion
MELLOTT, Judge:
This proceeding involves a deficiency in estate tax in the amount of $22,544.18. Respondent determined that decedent had made transfers, in contemplation of death and within two years prior to his death, of property having an aggregate value of $204,442.51. He included this amount in gross estate under section 811 (c) of the Internal Revenue Code. Inasmuch as $79,001.53 of the amount referred to had...
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