DRENNEN, Judge:
Respondent determined a deficiency in estate tax in the amount of $13,469.17. The issues for decision are (1) whether the transfer of certain real estate by decedent, pursuant to a divorce decree, to his wife for life with remainder in fee simple to his adult children, and in which he retained a primary life estate which was forfeitable upon default in the monthly alimony payments due, is includable in decedent's gross estate; and (2) in the...
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