SWAN, Circuit Judge.
The taxpayers are the executors under the will of Thomas Jefferson Newbold, who died on July 5, 1939, a resident of the state of New York. On December 30, 1924 the decedent created a trust of which he named himself and another the trustees. The question presented by the present proceeding is whether the full value, at the time of his death, of the corpus of this trust is required to be included in the settlor's gross estate under section 811(d...
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