Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
This proceeding involves a deficiency of $129,428.88 in estate tax.
The sole question for our consideration is whether three certain transfers were made by the decedent in contemplation of death within the meaning of section 811 (c) (1) (A) of the Internal Revenue Code.
The parties have agreed that certain administration expenses and attorneys' fees shall be determined upon hearing under...
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