Memorandum Findings of Fact and Opinion
OPPER, Judge:
By this proceeding petitioner challenges respondent's determination of an estate tax deficiency of $9,402.93.
The question involved is whether corpora of trusts created by decedent are includible in his gross estate by reason of a possibility of reverter; or by reason of his retained rights to determine the character of trust income as income or principal and thus prefer the respective remaindermen...
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