Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner determined a deficiency in estate tax in the amount of $41,298.33. The only issue for decision is whether the value, as of the date of death, of the corpus of a trust which was created by decedent on March 10, 1942, is includible in the gross estate under sections 811(c) or 811(d)(1) of the Internal
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