Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in estate tax liability in the amount of $1,953.60, consequent chiefly on his holding that the amount of $12,706.13, constituting the amount receivable as insurance under a life insurance policy taken out by the decedent upon his own life and representing the value of the policy on the applicable valuation date, was includible in the decedent's gross estate under the provisions of section...
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