Respondent has determined a deficiency of $160,761 in estate tax. The error assigned is upon respondent's action in including in the estate of the decedent the sum of $435,543.16, being the value upon the date of decedent's death of certain property conveyed by him in trust on or about January 23, 1924. The parties have filed a stipulation of facts, which we include herein by reference. Only such of the stipulated facts as are necessary to an understanding of the issue will...
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