KERN, Judge:
Respondent determined a deficiency of $8,763.08 in the estate tax of petitioner. That part of the deficiency is here at issue which results from respondent's including in the gross estate the amount of $60,477.93, representing the value of the rights of decedent's widow to receive as a joint annuitant amounts payable under a group annuity contract issued by Aetna Life Insurance Company...
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