Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Respondent has determined a deficiency in the estate tax of petitioners in the amount of $15,025.58. The issue here presented is whether the proceeds of a life insurance policy insuring the life of decedent wherein The J. T. Wing Company was the designated beneficiary and which corporation received such proceeds or upon whose debt a portion thereof was applied are includable in the taxable estate of...
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