Respondent determined a deficiency in the estate tax liability of decedent's estate in the amount of $10,326.80. The main question is whether there should be included in the value of the gross estate the value of certain remainder interests claimed by the executor to constitute a charitable bequest. Respondent determined that the bequest did not come within the terms of section 812 (d) of the Internal Revenue Code. Petitioner claims a refund of estate tax.
The Federal...
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