The Commissioner determined a deficiency of $39,889.07 in estate tax. The only issue for decision is whether he erred by including in the gross estate under section 811 (d) (1) an amount to represent the value of property in a trust created by the decedent on November 18, 1937.
FINDINGS OF FACT.
Frank Clowe died on August 22, 1946, while residing in Texas. He was then 62 years of age. The estate tax return was filed with the collector of internal revenue...
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