Memorandum Opinion
SCOTT, Judge:
Respondent determined a deficiency in the estate tax liability of the Estate of Samuel Ard, Jr., in the amount of $2,506,593.41. The parties disposed of most of the issues raised by the pleadings, by agreement, leaving for our decision only whether the proceeds of a life insurance policy on decedent's life, which was owned by his daughter, purchased within three years of decedent's death, are includable in decedent's gross...
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