PARKER, Judge:
Respondent determined a deficiency of $311,570.88 in petitioner's Federal estate tax. Petitioner claims an overpayment in estate tax in the amount of $25,414. The issue is whether, at the time of her death, Ethel H. Kurz (decedent) had a general power of appointment over a portion of a family trust that would cause such portion of the trust to be included in her gross estate under section 2041(a)(2).
Unless otherwise indicated, all section...
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