This proceeding was brought for a redetermination of a deficiency in estate tax of $23,710.23. Petitioner also makes a claim for overpayment of $8,277.88. The question presented is whether respondent erred in including in the gross estate of decedent an amount equal to the cost at the time of decedent's death of annuities for her surviving sister, decedent and her sister having purchased reciprocal survivor annuity contracts prior to March 3, 1931.
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