OPINION
QUEALY, Judge:
The respondent determined a deficiency in the Federal estate tax of the Estate of Robert R. Ware, deceased, in the amount of $290,729.03 of which the sum of $289,493.66 is in dispute. The petitioner is the executor of the estate.
The amount in dispute is attributable to respondent's inclusion in the decedent's gross estate of the value ($865,242.22) of five trusts created by the decedent. The only issue presented for...
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