Memorandum Opinion
TANNENWALD, Judge:
This case is before us on petitioner's motion for summary judgment. The sole issue for decision is whether irrevocable fractional interests in the corpus of the decedent's revocable trust, created in favor of her three children within 3 years of her death, must be included in the gross estate under sections 2035(d)(2)
At the time the petition was filed, petitioner...
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