Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in estate tax in the amount of $1,577,478.55. The questions presented for decision are:
(1) Whether certain inter vivos gifts made by the decedent to his wife and children directly and through trusts were made in contemplation of death or were intended to take effect in possession or enjoyment at or after his death and should, therefore, be included in the decedent's...
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