The respondent has determined a deficiency of $121,698.37 in the estate tax liability of the estate of Louise DeWitt Ruxton, deceased. The petitioner claims an overpayment in such amount as may result from the redetermination in the instant proceeding.
The principal issue is whether the respondent erred in including in the decedent's gross estate the amount of $270,315.16 based upon his determination that certain trusts created by the decedent and her husband on August...
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