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ESTATE OF GREEN v. COMMISSIONER

Docket No. 3274-74.

64 T.C. 1049 (1975)

ESTATE OF MARGUERITE M. GREEN, DECEASED, AND VIRGINIA G. PAUL AND FRANCIS W. GREEN, JR., CO-EXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 17, 1975.

Attorney(s) appearing for the Case

Kenneth G. Anderson and Robert S. Bolt, for the petitioners.

Thomas M. Cryan, for the respondent.

RAUM, Judge:

The Commissioner determined a deficiency in decedent's Federal estate tax in the amount of $304,482.07. Both parties have made certain concessions, and the principal issues remaining for decision are the following:

(1) Did decedent, in respect of property which she transferred in trust, retain an interest therein which would require the inclusion of its value in her gross estate pursuant to section 2036(a)(1), I.R.C. 1954?

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