Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $2,513,219.99 in estate tax. The issues for decision are (1) whether the value of the corpus of each of six trusts is includible in the gross estate under section 811 (a), (c), (d) or (f); (2) whether proceeds of 17 policies of insurance on the life of the decedent, in excess of the amounts reported on the estate tax return, are includible in the gross estate under either section...
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