Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in estate tax of $28,931.66. The deficiency resulted in part from the inclusion in the gross estate of the value of property which was transferred by the decedent to a trust during his lifetime. The parties have stipulated that the value of the trust property was $87,920.64 at the date of death.
The sole issue is whether the Commissioner...
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