OPINION.
MULRONEY, Judge:
Respondent determined a deficiency in estate tax of petitioner estate in the sum of $18,132.14. The sole question in the case is whether certain trust property, the income of which was payable to decedent for his life, should be included in his estate under section 811 (c) (1) (B) of the Internal Revenue Code of 1939, on the ground that he had made a "transfer" of such property in trust and retained a life income.
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