Memorandum Opinion
DISNEY, Judge:
This case involves Federal estate tax. Deficiency was determined in the amount of $79,464.42, all of which is placed in issue, and petitioners claim overpayment of $3,688.58. The question presented is whether the value of remainders after the life interests of primary beneficiaries under trusts created by the decedent, Rebecca L. Elias, is included in gross estate as transfers...
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