OPINION.
ATKINS, Judge:
The respondent determined a deficiency in estate tax in the amount of $341,369.15 which resulted from several adjustments made by him, but principally from the inclusion in the decedent's gross estate, at a value of $795,395.02, of assets of three trusts which the decedent had created during his lifetime. By agreement between the parties all issues have been settled except that relating to the respondent's inclusion of the...
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