MULRONEY, Judge:
The respondent determined a deficiency in the estate tax of the Estate of Florence B. Moreno in the amount of $38,649.89. The sole issue in the case is whether the value of the insurance trust of decedent's husband, Theodore, is includible in decedent's estate for Federal estate tax purposes under section 811 (c) (1) (B) and (c) (1) (C), Internal Revenue Code of 1939.
FINDINGS OF FACT.
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