Memorandum Findings of Fact and Opinion
HARLAN, Judge:
Petitioner seeks a redetermination of a deficiency in estate tax in the amount of $61,204.30. This proceeding presents two questions:
(1) Were the gifts amounting to approximately $213,000 in value to decedent's children, grandchildren, sons-in-law and daughters-in-law, made in contemplation of death?
(2) Under the circumstances in this case, is an attorney fee of $10,000 excessive?<...
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