Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency of $32,230.63 in estate tax.
Certain issues raised in the pleadings were disposed of by agreement of the parties prior to the trial herein. The sole issue left for decision is whether the value of 100 shares of stock in C. M. Neilson & Son, Inc., and of three savings accounts is includable in the gross estate of Chris M. Neilson under section 2035.
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