Respondent has determined a deficiency in estate tax in the sum of $34,509.26. The two issues presented are whether the value of the corpus of an inter vivos trust created by petitioners' decedent on November 17, 1928, is includible in her gross estate pursuant to the provisions of section 811 (c), Internal Revenue Code, (1) as a transfer by trust intended to take effect in possession or enjoyment at or after decedent's death, or (2) as a transfer in contemplation...
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