OPINION.
SCOTT, Judge:
Respondent determined a deficiency in estate tax in the amount of $110,691.35 for the Estate of Newcomb Carlton.
The issue for decision is whether the entire proceeds of insurance policies, or any part thereof, and the value of securities transferred in trust by decedent are includible in his gross estate.
In his notice of deficiency respondent determined that "the entire proceeds of life insurance policies aggregating...
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