Memorandum Findings of Fact and Opinion
These cases were consolidated for hearing. In both the deficiencies have been determined against the petitioners as transferees of assets of the Estate of Edward H. Simmons, deceased; in No. 774, against testamentary trustees of the estate; and in No. 1858 against the decedent's daughter who was the beneficiary of the insurance policy in question. The Commissioner has determined a deficiency in the estate tax of Edward H....
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