The respondent determined a deficiency in estate tax against the estate of Margaret P. Gallois in the amount of $19,323.36.
The single issue in controversy is whether the entire value at the date of death of the corpus of a trust created by her on August 9, 1924, is includible in the decedent's gross estate under the provisions of section 811 (c) of the Internal Revenue Code. Another issue raised by the pleadings has been abandoned by the petitioners.
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