Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in estate tax in the amount of $31,185.03. The deficiency resulted from respondent's action in including in the gross estate of decedent the proceeds of three insurance policies taken out by decedent upon his own life and subsequently assigned to his three sons. Whether or not such proceeds were includible in decedent's gross estate under the provisions of section 811 (c) of the Internal...
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