Respondent determined a deficiency in Federal estate tax of $162,072.88. The issues remaining for decision are: (1) Whether, in respect of the three trusts, the enjoyment thereof was subject at the date of decedent's death to any change through the exercise of a power by decedent to alter, amend, or revoke under section 2038 of the 1954 Code; or the right existed in decedent at a time not ascertainable without reference to his death to designate the persons who shall possess...
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