The Commissioner determined a deficiency of $264,117.41 in estate tax. The parties have filed a stipulation in which they have settled some of the issues. The first issue for decision is whether the value of property which the decedent transferred in trust on June 23, 1933, should be included in the gross estate either under section 811 (d) (2), because the decedent retained the power to revoke the trust, or under (d) (4), because he reliquished the power of revocation in...
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