Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent has determined a deficiency in estate tax in the sum of $59,324.42. The issues are: (a) whether the value at the time of the death of the decedent of property transferred by him in trust, which trust was later amended, is includible in the gross estate of the decedent under the provisions of section 811 (c) and (d) (2) of the Internal Revenue Code; (b) whether or not, in the event that the...
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