OPINION
SCOTT, Judge:
Respondent determined a deficiency in the estate tax of Elena B. Drake in the amount of $23,372.75. Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for our decision the following:
(1) Whether certain real property which was transferred by decedent in contemplation of death to herself and her husband as joint tenants with right of survivorship is properly includable...
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