OPINION.
RAUM, Judge:
Respondent has determined a deficiency in estate tax in the amount of $34,612.47 with respect to the Estate of Carrie Grossman, who died in 1951. The sole issue is whether the principal of a trust established by her in 1930 is includible in her gross estate under section 811 (d) (2) of the Internal Revenue Code of 1939. The facts have been stipulated.
On December 20, 1930, the decedent created a trust for the benefit...
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