Memorandum Findings of Fact and Opinion
WILLIAMS, Judge:
The Commissioner determined a deficiency in petitioner's Federal estate tax in the amount of $61,150.78. The issue we must decide is whether decedent's one-third fee interest in White Hall Farm, which he transferred to his son-in-law in 1975, is includable in his estate either as a retained life estate pursuant to section 2036(a)(1)
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