OPINION
RAUM, Judge:
The Commissioner determined a deficiency in the estate tax of the Estate of Max J. Gorby in the amount of $92,120.15. The only issue remaining with respect to that deficiency is whether decedent retained sufficient incidents of ownership in two group term life insurance policies to render them includable in his gross estate pursuant to section 2042(2), I.R.C. 1954. The facts have been stipulated.
The decedent, Max J. Gorby...
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