Memorandum Opinion
DAWSON, Chief Judge:
Respondent determined a deficiency in Federal estate tax due from the estate of Gladys F. Bothun in the amount of $2,457.58. The sole issue for decision is whether there was a lifetime transfer by the decedent of her interest in a life insurance policy on the life of her husband, so as to require inclusion of the proceeds in decedent's gross estate under one or all of sections 2036, 2037 or 2038.
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