Memorandum Findings of Fact and Opinion
FISHER, Judge:
The respondent determined a deficiency in estate taxes in the amount of $17,288.37. The sole issue before us is whether a bequest in trust qualifies for the marital deduction within the provisions of section 812(e)(1)(F) of the Internal Revenue Code of 1939 where the surviving spouse was not entitled to all of the income from the trust and her power to appoint by will was limited to one-half of the corpus...
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