The Commissioner determined a deficiency in estate tax of $35,565.27. Part of the deficiency is conceded. The amount of the deficiency which is contested by the petitioner is $16,556.45. The question to be decided is whether two separate trusts were created by an amended trust agreement executed by the decedent during his lifetime. The petitioner asserts that the agreement created two trusts, and claims the marital deduction provided for in section 812 (e) (1) of the Internal...
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