This proceeding involves an estate tax deficiency of $48,994.62. Among other lesser adjustments not in controversy the respondent has added to the value of decedent's net estate as reported $178,648.94 representing the net value of the corpus of an insurance trust which decedent created in 1936, four years prior to his death. Whether the proceeds of the policies assigned to the trust are includible in decedent's gross estate is the only question for our determination.
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