OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $136,150.93 in estate tax. The only issue for decision is whether the Commissioner erred in determining that a portion of the value of a trust created by the decedent on January 2, 1919, should be included in his gross estate under section 811 (a) of the Internal Revenue Code. Another issue relating to administration expenses incident to the prosecution of this proceeding requires...
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