OPINION
DAWSON, Judge:
Respondent determined a deficiency in the estate tax of petitioners in the amount of $8,254.98.
The issues for decision are:
(1) Whether the value of a power of appointment over the corpus of a trust created under the will of Stirling Van Winkle, deceased, should be included in the gross estate of Mabel C. Van Winkle, deceased.
(2) Whether petitioners are entitled to a credit for prior estate tax paid...
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