Memorandum Opinion
RAUM, Judge:
The Commissioner determined a Federal estate tax deficiency of $405,209.03 (less $61,275.27 additional credit for State death taxes, if substantiated). After concessions, the only matter in controversy is whether the value of assets of a trust of which Victor J. Strauss (Victor or the decedent) was a beneficiary and a trustee is includable in his gross estate
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