Respondent determined a deficiency in the estate tax of the petitioner in the amount of $10,292.87. Petitioner acquiesced in certain adjustments and paid additional taxes thereon in the amount of $297.86. The issue for decision is whether the respondent correctly determined that the entire corpus of a trust created by the petitioner's decedent was includible in the gross estate under section 811 (c) (1) (B) of the Internal Revenue Code of 1939.
FINDINGS OF FACT....
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