OPINION.
TIETJENS, Judge:
This proceeding involves a deficiency of $497,815.02 in estate tax. The several issues settled by stipulation will be reflected in the computation under Rule 50. The questions still at issue are: (1) Whether the value of stock dividends paid on stock between the time of its transfer in contemplation of death and the death of the transferor is includible in decedent's gross estate under section 811 (c), Internal Revenue Code...
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