Memorandum Findings of Fact and Opinion
HARRON, Judge:
Respondent has determined a deficiency in estate tax in the amount of $195,388.28. Certain adjustments are not contested. Other adjustments have been resolved by stipulation. The sole issue remaining for decision relates to the inclusion in the gross estate of the proceeds of two life insurance policies upon the life of decedent which policies decedent, prior to his death, had assigned to his wife.<...
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