This case involves estate tax. A deficiency was determined in the amount of $40,548.81. The questions presented, after abandonment of some minor issues, are (a) whether an agreement between the decedent and his wife on December 2, 1942, dividing their property into tenancy in common, was in contemplation of death within the meaning of section 811 (c) and (d) (5) of the Internal Revenue Code; (b) whether, if the agreement was in contemplation of death, it was made for adequate...
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