OPINION.
FISHER, Judge:
This case involves an estate tax deficiency of $104,017.55, resulting from the inclusion in decedent's gross estate of property transferred in trust having a value of $205,698.57, at the date of decedent's death. Inclusion of this property was based upon section 811(c)(1)(B) of the 1939 Code as amended by section 207(a) of the Technical Changes Act of 1953.
All of the facts are stipulated and are incorporated herein...
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