Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined an estate tax deficiency in the amount of $196,283.67, as a result of including in the gross estate the value of a remainder interest in a trust which had been created by the decedent, Jennie E. Hinde, on December 31, 1930. The sole question presented for decision is whether that transfer in trust was made in contemplation of death. Section 811 (c), Internal Revenue Code.
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