Memorandum Findings of Fact and Opinion
The respondent determined a deficiency of $29,284.33 in estate tax.
The issues are: (1) whether the respondent erred in including in the gross estate the value of property transferred by decedent to a trust as a transfer made in contemplation of death; (2) in the alternative, is the value of a trust executed by the decedent's husband on the same date includible in the decedent's gross estate under the reciprocal trust...
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