Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined a deficiency of $61,282.37 in estate tax of the estate of Mary R. D. Torrance, hereinafter referred to as decedent. The single issue presented is whether decedent's transfers of stock to her daughter and grandchildren were transfers in contemplation of death within the purview of Internal Revenue Code, section 811 (c).
Some of the facts have been stipulated.
Findings...
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