This proceeding involves the redetermination of a deficiency of $51,817.64 in estate tax. The issues are whether the value of the corpus of a trust created in 1933, of which decedent's daughter was named as grantor, and a trust created by the decedent in 1923, are includible in the decedent's gross estate. We shall, for the sake of clarity, treat the two trusts separately.
FINDINGS OF FACT AS...
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