Memorandum Findings of Fact and Opinion
KERN, Judge:
Respondent has determined a deficiency in estate tax in the amount of $70,675.28. The sole issue presented is whether the respondent erred in his determination by reason of including in decedent's gross estate the value of a trust created by decedent on February 17, 1928 in reliance upon section 811 (c) of the Internal Revenue Code.
[The Facts]
On that date decedent made a transfer...
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