The respondent has determined a deficiency in estate tax in the amount of $37,314.12. There are two questions for decision: (1) Whether the value at the date of the decedent's death of the life estate of Alice F. Mitchell, who was the wife of the decedent at the time of his death, in an inter vivos trust, is includible in the gross estate under section 811 (c) of the Internal Revenue Code as a transfer intended to take effect at or after death. (2) Whether, in determining...
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