The Commissioner determined a deficiency in the estate tax in the amount of $14,413.29. Respondent's adjustment decreasing the marital deduction was not contested. The sole issue for decision is whether the Commissioner correctly determined that the proceeds of two insurance policies which were made available to decedent's divorced spouse were includible in decedent's gross estate, and that the estate was not entitled to an offsetting deduction.
FINDINGS OF FACT...
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