Respondent has determined a deficiency in estate tax in the amount of $13,740.43. There is one issue for decision; whether the corpus of an irrevocable trust which the decedent created on April 19, 1930, is includible in her gross estate under section 811 (c) of the Internal Revenue Code, as amended.
The parties have stipulated that attorney fees and expenses in connection with this proceeding which constitute proper deductions from the gross estate will be allowed...
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