OPINION.
SMITH, Judge:
This proceeding is for the redetermination of a deficiency in estate tax in the amount of $3,393,543.99. A number of issues presented have been disposed of by a stipulation of the parties. The issues for decision are:
(1) Whether section 811 (c) of the Internal Revenue Code, in so far as it requires that there shall be included in the gross estate of the decedent the value of the corpus of an inter vivos trust...
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