MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge:
Respondent determined a deficiency of $163,677.55 in Federal estate tax (estate tax) with respect to the estate (estate) of Sarah W. Greve (decedent). The issues for decision are:
(1) Is certain property with respect to which decedent had a power of appointment at the time of her death includible in decedent's gross estate under section 2041(a)(1)?
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