The Commissioner determined a deficiency in estate tax in the amount of $222,607.99. The petitioners claim that there is no deficiency; they claim, further, that there is overpayment of estate tax in the amount of $17,503.04.
The Commissioner has receded from certain determinations. One issue remains for decision, whether the decedent had a vested interest, under the will of the settlor of a testamentary trust, in trust income (one-ninth) during the term of the trust...
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