Memorandum Findings of Fact and Opinion
LEMIRE, Judge:
This proceeding involves an estate tax deficiency of $130,149.88. The decedent was a resident of Montgomery County, Pennsylvania, and his estate tax return was filed with the collector of internal revenue for the first district of Pennsylvania. The principal issue involved is whether the respondent erred in including in decedent's gross estate the value of the remainder interests in three inter vivos...
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