Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The respondent determined a deficiency in petitioner's estate tax in the amount of $422,061.60. The issue is whether the value of 58 certificates of beneficial interest in a trust, held of record by decedent's children, is includable in decedent's estate.
Findings of Fact
Some of the facts are stipulated and they are found accordingly.
Alex Pielet, hereinafter called "Decedent...
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