OPINION.
LEECH, Judge:
This proceeding involves a deficiency in estate tax in the amount of $231,756.27. The sole contested issue is whether the corpora of two trusts are includible in decedent's gross estate as trusts intended to take effect in possession or enjoyment at or after decedent's death, within the provisions of section 302 (c) of the Revenue Act of 1926, as amended. All the facts have been stipulated and are so found. They may be summarized...
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