MEMORANDUM OPINION
TANNENWALD, Judge:
Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $152,080. The sole issue for decision is whether the value of certain units of beneficial interest in an Illinois land trust should be included in decedent's gross estate under section 2036 or 2038.
All the facts have been stipulated. The stipulation of facts and attached exhibits are incorporated...
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