Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined a deficiency of $50,076.01 in petitioner's Federal estate tax. The only issue for our determination is whether certain transfers made by or on behalf of decedent Gertrude H. Schwab (decedent) within three years of her death were made in contemplation of death within the meaning of section 2035 of the Internal Revenue Code of 1954.
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