Memorandum Opinion
OPPER, Judge:
A deficiency in estate tax in the amount of $532,182.34 is the subject of the present controversy, but only part is in issue. That part of the deficiency arises by reason of the respondent's inclusion in the gross estate of petitioner's decedent of the entire corpus of a trust created by the decedent during his life.
All of the facts have been stipulated and are hereby found accordingly. The Federal estate tax return...
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