Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined a deficiency of $40,399.73 in the Federal estate tax of the Estate of Antonia B. Vogel. The sole issue for decision is whether certain shares of stock transferred by decedent to herself as custodian for three minor grandchildren are includable in her gross estate pursuant to section 2038.
Findings of Fact
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