Memorandum Findings of Fact and Opinion
MELLOTT, Judge:
This proceeding involves a deficiency in Federal estate taxes in the amount of $9,109.08. The pleadings raise two issues: (1) whether certain transfers of real estate made by the decedent in her lifetime should, for estate tax purposes, be deemed to have been made in contemplation of death or intended to take effect in possession and enjoyment at or after death and hence included in the gross estate...
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