OPINION
RAUM, Judge:
The Commissioner determined a deficiency in the estate tax of the Estate of Hector R. Skifter in the amount of $53,776.77. Two issues remain for decision with respect to that deficiency: (1) Whether decedent possessed sufficient incidents of ownership in nine insurance policies on his life to render the amounts receivable by the beneficiaries under the policies includable in decedent's gross estate pursuant to section 2042(2)...
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