Memorandum Opinion
STERNHAGEN, Judge:
The Commissioner determined a deficiency of $9,582.07 in estate tax. The petitioner assails the inclusion in gross estate of $19,508.31, the value one year after death of a possible reversionary interest under a trust created by decedent during his lifetime. By amended answer the respondent alleges that instead of $19,508.31 the value was $65,333.20 or at least $39,882.87.
The facts are all stipulated.
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