Memorandum Findings of Fact and Opinion
SMITH, Judge:
This proceeding involves an estate tax deficiency of $99,033.28. Some of the issues raised by the pleadings have been settled by stipulation, some have been waived by petitioners, and some have been conceded by the respondent in his brief. The questions remaining for our determination are:
(1) Whether there should be included in the gross estate as a transfer in contemplation of death the value...
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