The Commissioner determined a deficiency of $104,350.08 in estate tax. The petitioner alleges that the Commissioner erred in adding to the gross estate as reported $341,102.02, the value at the date of death of property in a trust created by the decedent on December 30, 1936, and, in the alternative, in adding to the gross estate the income earned by the trust between December 30, 1936, the date of its creation, and December 11, 1944, the date of the death of the decedent...
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