Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $127,727.58 in estate tax liability.
The principal issue is whether certain property transferred in trust by decedent during his lifetime is includible in the gross estate under sections 811 (c) and (d) of the Internal Revenue Code. Other issues concern the amount of property held in trust and deduction of additional legal and administration fees.
Findings of Fact...
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