Memorandum Findings of Fact and Opinion
OPPER, Judge:
By this proceeding petitioner seeks a redetermination of a deficiency in estate tax of $16,288.51.
The issue is the propriety of the inclusion of certain property conveyed in trust by decedent prior to his death in his gross estate under the provisions of Internal Revenue Code, section 811.
Findings of Fact
The stipulated facts are hereby found accordingly, of which the following...
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