DRENNEN, Judge:
Respondent determined a deficiency of $155,563.13 in the Federal estate tax liability of the Estate of Francis M. Hendry. The only issues for decision are: (1) Whether decedent retained such an interest in a 655-acre residence-ranch which he transferred to his wife in 1948 as to make the value thereof includable in his gross estate under section 2036(a)(1), I.R.C. 1954; and (2) whether the balance due, in the amount of $155,000, on three notes...
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