The respondent determined a deficiency of $26,751.63 in the estate tax liability of the Estate of Frederick John Twogood, deceased.
The primary issue is whether or not the decedent made a transfer within the meaning of section 811 (c) of the Internal Revenue Code in electing to receive a reduced annuity in order that his wife would also receive an annuity in the event of her survivorship.
In the event that it is decided that a transfer was made as contemplated...
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