Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $294,063.55 in estate tax. The following questions have been submitted for decision:
(1) Should the value of a 1935 inter vivos gift by the decedent to his wife be included in the gross estate under the provisions of sections 811 (c) either as a transfer made with the possession or enjoyment, or the right to income, retained by the decedent or as a transfer made in...
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