The respondent has determined an estate tax deficiency against the estate of Mary H. Hays, deceased, in the amount of $17,165.19. The only question in issue is the inclusion in the gross estate of the value of four tracts of farm land comprising 2,713 acres of an admitted net value of $70,660.80, which the decedent transferred during her lifetime to a trust, of which she was the sole trustee, for the benefit of her four adult children. There is no dispute as to the basic...
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