OPINION.
LEECH, Judge:
This controversy involves a deficiency in estate tax amounting to $118,747.12. The sole contested issue is whether the respondent erred in including the value of the trust remainders in decedent's gross estate. All the facts were stipulated and are adopted as stipulated.
Petitioners are the duly qualified executors of the estate of Charles M. Thorp, deceased, a resident of Pittsburgh, Pennsylvania, who died testate on...
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