Memorandum Opinion
SMITH, Judge:
This proceeding involves an estate tax deficiency of $11,609.69. The sole question in issue is whether the respondent correctly included in decedent's gross estate the remainder values of three trusts which decedent created during her lifetime.
The facts are stipulated.
[The Facts]
Decedent died testate on May 28, 1939, at the age of 87, a resident of Rochester, New York. An estate tax return...
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