Memorandum Findings of Fact and Opinion
DISNEY, Judge:
This proceeding involves a deficiency of $215,784.82 in estate tax. The issues are whether the value of certain property and the cost of an annuity should be included in the gross estate as transfers in contemplation of death; whether certain installment payments aggregating $16,500 payable to the decedent on the day of her death constitute part of the gross estate, and whether respondent erred in disallowing...
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