Memorandum Findings of Fact and Opinion
HILL, Judge:
This proceeding involves an estate tax deficiency in the amount of $9,625.44. The sole issue is whether the entire corpus of a fund over which decedent had and exercised a testamentary general power of appointment should be included in the decedent's gross estate where the appointee was the same as the taker in default and received less than he would have received in default.
The estate tax return...
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