Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in estate tax in the Estate of Joseph C. Wilson in the amount of $19,029,055.92. Certain minor issues raised by the pleadings have been abandoned or disposed of by agreement of the parties, leaving for decision the following:
(1) Whether gifts of approximately $12 million made by decedent to his children in trust within 3 years of his death were transfers in...
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