Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency of $199,260 in petitioner's Federal estate tax. The issues presented are (1) whether the gross estate should include the value of life insurance policies on decedent's life and (2) whether the gross estate should include the value of proceeds receivable from life insurance policies on decedent's life.
Findings of Fact
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