OPINION.
SCOTT, Judge:
Respondent determined a deficiency in petitioner's estate tax in the amount of $88,941.53. Concessions of each party are to be reflected in a computation under Rule 50.
The sole issue remaining for decision is the correctness of respondent's action in including in the gross estate of the decedent, Leo M. Gartland, the amount of $258,968.29, representing the value of the corpus of a trust created by Matthew F. Gartland...
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