RAUM, Judge:
The Commissioner determined a deficiency of $170,374.35 in the estate tax of the Estate of Arthur J. O'Connor. The only issue remaining for decision is whether four trusts created by the decedent and his wife are includable in his gross estate under section 2036 or section 2038, I.R.C. 1954. The facts have been stipulated.
The decedent, Arthur J. O'Connor (O'Connor), died testate...
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