Memorandum Opinion
FAY, Judge:
Respondent determined a deficiency in petitioner's estate tax in the amount of $129,683.28.
The sole issue for decision is whether the entire corpus of a trust created in 1905 by Sarah F. Bremer, deceased (hereinafter referred to as decedent), wherein she reserved the income for life and a general testamentary power of appointment over the corpus is includable in her gross estate under section 2036(a) of the Internal...
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