Respondent determined a deficiency in estate tax in the amount of $123,053.33. The question is whether there should be included in the gross estate of the decedent, Clothilde K. Lueders, under section 811 (a), (c), or (d) of the Internal Revenue Code, the value on the date of decedent's death of the corpus of a trust which was created by her husband during his lifetime. The value of that trust at the date of decedent's death was $363,988.55. At the hearing respondent stated...
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