The respondent determined a deficiency in estate tax in the amount of $374,243.55. The chief issue is whether the respondent erred in including in the gross estate of the decedent, Elizabeth W. Vease, the value of properties held in trusts in which the decedent was the income beneficiary for life and with respect to which she had a limited, testamentary power of appointment. The primary question under this issue is whether the decedent's interests in the trusts were acquired...
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