Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined a deficiency of $19,441.83 in petitioners' estate tax for the year 1948. The sole contested issue is whether a transfer by the decedent of certain shares of common stock in 1941 constituted a transfer made in contemplation of death or a transfer in which decedent retained possession or enjoyment of, or the right to the income from, the property until his death within the meaning...
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